From Stablecoins to ‘Digital Bills of Exchange’: Why Monitoring After Sanctions Implementation Is Critically Important

When another package of sanctions against an aggressor country comes into force, it may seem that the financial flows of its regime are about to dry up. In reality, sanctions are not the finish line, but only the beginning of a new round of confrontation. The rouble-pegged stablecoin A7A5, which facilitated transfer of US$ 9.3 billion in Russian funds within just four months, and the transfers of 4.5 billion A7A5 tokens from wallets at Garantex to Grinex – are two vivid examples of such confrontation. In this article, the authors look at how the A7A5-Grinex scheme works, why it became possible, and what lessons can be learnt for effective sanctions control.

This article is co-authored by Astraea’s James Ramsden KC and Dr Khrystyna Khanas, with Dr Tetiana Dmytrenko – Founder and Chair of NGO ‘Ukrainian Modern Digital Science’, Chair of the Finance Committee of the Public Council of the Ministry of Finance of Ukraine, a member of the Public Council under the State Financial Monitoring Service (FIU) of Ukraine.

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