Iranian and Russian based crypto addresses sanctioned by OFAC

A series of crypto wallet addresses including Bitcoin (BTC), Ethereum (ETH) and Tether (USDT) were added to the US SDN sanctions list by OFAC in September. The addresses belong to Iranian ransomware attackers and a neo-Nazi Russian paramilitary group Task Force Rusich. Task Force Rusich is known to be affiliated with The Wagner Group, which is also sanctioned by OFAC.

Sanctions teams should be wary about the potential for sanctioned entities to leverage the ability to move between crypto assets and blockchains in an attempt to obscure illicit activity. 

Wave of new sanctions aims to cut off professional services to Russia

In response to the illegal annexation of several regions of Ukraine by Russia, the UK government have announced a series of new sanctions which will cut off Russia’s access to:

• IT consultancy services
• architectural services
• engineering services
• advertising services
• transactional legal advisory services
• auditing services

A further 700 goods crucial to Russian industry have been added to the export ban. These moves come alongside actions by Europe and the US. Additionally, the governor of Russia’s Central Bank, Elvira Nabiullina, has also been subjected to a travel ban and an asset freeze.

A guide to understanding and using sanctions lists

Sanctions are a diplomatic tool used to promote international peace and security and to combat violations of international law and terrorism. They do this by applying economic pressure on a country or regime by restricting dealings with the regime, as well as certain individuals and entities. The goal of using sanctions is to pressure a regime to change its behaviour regarding certain political, military, or social issues. 

Sanctions are legal limitations put in place by individual countries like the United Kingdom or the United States, or by international institutions, such as the United Nations (UN) and the European Union (EU). They may include various forms of trade barriers, from tariffs and restrictions on financial transactions to broad embargoes. 

Understanding why businesses get fined

All businesses must comply with sanctions laws. Failure to do so is a criminal offence. In recent weeks, new laws in the UK have made breaching sanctions rules a strict liability offence. This means there’s no requirement for the business to have intended to breach sanctions. The fact that it happened is enough for a monetary penalty to be levied.

What is a breach of financial sanctions?

A breach of financial sanctions refers to the violation or non-compliance with measures imposed by regulatory authorities or international organisations to restrict financial transactions with specific individuals, organisations, or countries. These sanctions are typically imposed due to concerns about national security, human rights, or international peacekeeping.

Such breaches can occur when individuals, businesses, or financial institutions knowingly or unknowingly engage in prohibited activities, such as providing financial support, conducting transactions, or facilitating trade with sanctioned entities.