In response to Russia’s invasion of Ukraine, the US and European governments have imposed numerous sanctions, embargos, and export controls on the country. These apply not just to traditional financial institutions but to cryptocurrency businesses, which face unique compliance challenges.
Brattle Principal Paul Hinton has coauthored a recent Bloomberg Law article with former Assistant US Attorney Sid Kamaraju of Pryor Cashman detailing some of the sanctions compliance challenges that both traditional finance and the crypto industry face. The article also identifies the limitations of surveillance strategies centered on list-based screening and examines how past regulatory investigations demonstrate the need for a sophisticated implementation of a risk-based approach to avoid enforcement actions.
The full article, “Navigating Russia Sanctions Compliance in the Crypto Space,” is available below.