Sanctions and the Russia-Ukraine War

Challenge

An FRA Senior Associate, while an intelligence analyst at a well-known blockchain analytics company, was responsible for monitoring and investigating cryptocurrency sanctions exposure originating from the Russia-Ukraine war to protect customers from sanctions violations. Given the dynamic nature of the war and severity of sanctions enforcement programs, the Senior Associate was required to establish a robust and holistic program to identify and mitigate customer risk exposure and perpetually update it to keep pace with evolving evasion techniques.

Action

The FRA Senior Associate expanded upon global sanctions lists with on-chain cryptocurrency investigations, open-source research, and undercover operations to establish a comprehensive program to identify cryptocurrency addresses controlled by sanctioned individuals and groups. Combining constant monitoring of global sanctions lists with proactive investigative efforts, the Senior Associate identified numerous cryptocurrency addresses and entities not explicitly named on sanctions lists, but subject to sanctions enforcement.

Result

The FRA Senior Associate was able to create and maintain an exhaustive screening database of thousands of crypto addresses for leading law enforcement agencies, regulators, and virtual asset service providers across dozens of countries to use as part of their sanctions compliance and investigative programs, and proactively disseminated targeted notifications to customers based upon real-time risk exposure.