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Enhancing the EU Response to Crypto-Enabled Sanctions Circumvention

Enhancing the EU Response to Crypto-Enabled Sanctions Circumvention

But stablecoin ecosystems are not monolithic. Issuers may have direct customers with whom they maintain a formal relationship, but many users interact with stablecoins on secondary markets through exchanges, brokers or decentralised platforms. This distinction matters for sanctions implementation. The issuer may be able to freeze assets in some circumstances, but it may not have a direct relationship with every user of the token. Despite this, and although exchanges and other liquidity providers play a central role in limiting sanctions evasion, stablecoin issuers should not be allowed a free pass and the EU should exert greater pressure on issuers to enforce greater integrity on their clients, just as just as the issuers and…

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