Cryptoasset exchanges that maintain operational or financial connections with Russia continue to enable sanctions circumvention, providing transaction routes that allow Russian entities to make cross-border payments shielded from traditional banking oversight. Fiat currencies such as rubles can be converted into cryptoassets through these services, before being transferred across borders, without passing through any intermediaries. They can then be converted to local currency through overseas cryptoasset brokers or exchanges.

Bitpapa is a peer-to-peer (P2P) cryptoasset exchange with corporate registrations in the UAE, but it primarily targets users in Russia, allowing rubles to be exchanged for a range of cryptoassets. It was sanctioned by OFAC in March 2024 for supporting Russian sanctions evasion. Evidence of its role in evasion includes that approximately 9.7% of its outgoing crypto funds are destined for OFAC-sanctioned targets, including 5% to Garantex. Blockchain analysis suggests Bitpapa rotates wallets to evade sanctions enforcement, a tactic designed to prevent transaction monitoring systems from identifying Bitpapa as a counterparty and to obscure the Russian origin of funds.

Exmo’s case shows that claimed geographic separation is contradicted by on-chain data. After the 2022 invasion, Exmo said it exited the Russian market by selling to Exmo.me, but on-chain analysis indicates Exmo.com and Exmo.me share custodial wallets. Crypto assets deposited into both platforms are pooled into identical hot wallets, and withdrawals are issued from the same addresses. This indicates there is no real separation at an operational level, allowing funds from the Russian-facing platform to be co-mingled with the Western-facing entity.

Rapira is a Georgia-incorporated exchange with a Moscow office that facilitates ruble-based trading. It has engaged in direct cryptoasset transactions to and from the sanctioned exchange Grinex totaling more than $72 million. Rapira’s Moscow offices were reportedly raided as part of an investigation into suspected capital flight to Dubai.

Aifory Pro specializes in cash-to-cryptoasset services in Moscow, Dubai and Türkiye, and serves as a Foreign Economic Activity Payment Agent for international trade, for example between Russia and China. It explicitly facilitates the bypass of service restrictions by offering virtual payment cards and Apple Pay-enabled cards that utilize a customer’s USDT balance to pay for foreign services like Airbnb and ChatGPT, otherwise blocked in Russia. Further evidence of high-risk activity includes its direct financial links to Abantether, an Iranian exchange, to which it has sent nearly $2 million in cryptoassets.

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