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Crypto execs signal their readiness to comply with sanctions, but decentralization itself puts crypto in a vulnerable position.

It has been two weeks since Russia kicked off the first large-scale military action in Europe in the 21st century — a so-called “special operation” in Ukraine. The military conflict immediately triggered devastating sanctions against the Russian economy from the United States, the European Union and their allies and has put the crypto industry in a position that is both highly vulnerable and demanding.

As the world watches closely, the crypto space must prove its own standing as a mature and financially and politically responsible community, and it must defy the allegations of being a safe haven for war criminals, authoritarian regimes and sanctioned oligarchs. Up to this point, it has been going relatively well. But despite reassurances from industry opinion leaders, some experts say that crypto’s decentralized nature might seriously jeopardize the effort.

The donations precedent

Amid the wave of support for Ukraine from citizens, institutions and governments across the globe, the nation set a crucial precedent. On Feb. 26, the third day of Russia’s military operation, the Ukrainian government announced that it would accept donations via crypto. It made the statement on Twitter and listed Bitcoin (BTC), Ether (ETH) and Tether (USDT) wallet addresses. It came as the official approval of a similar previous announcement from the nation’s 31-year-old, digital-savvy deputy prime minister, Mykhailo Fedorov.

The idea of a distressed European country officially accepting digital assets from those ready to extend a helping hand sounded so shocking that even Vitalik Buterin initially doubted the statement's authenticity. But Tomicah Tillemann, former senior adviser to two U.S. secretaries of state, confirmed the validity of the wallets, citing a former Ukraine ambassador. Kyiv-based cryptocurrency exchange Kuna Exchange put together and manages the infrastructure for donations.

Blockchain analytics firm Elliptic has estimated that these wallets, and those of another Ukraine-related initiative called “Come Back Home,” have received north of $63 million in crypto as of March 9. The money came from more than 120,000 individual donations.

Donors include Polkadot founder Gavin Wood, who sent $5.8 million; the anonymous sender of a donation worth $1.86 million, which “appears to have come from the proceeds of the sale of NFTs created by Julian Assange and the digital artist Pak”; and Chain.com CEO Deepak Thapliyal, who donated about $290,000. However, the vast majority of the donations have come from ordinary individuals and are less than $100.

A separate initiative called UkraineDAO was launched at the beginning of the war by Nadezhda Tolokonnikova, who is a member of Russian activist group Pussy Riot, alongside Trippy from Trippy Labs and PleasrDAO members. Raising ETH via PartyBid, UkraineDAO gathered donations from prominent tech individuals and entities such as online subscription platform OnlyFans and Reddit co-founder Alexis Ohanian. By March 3, UkraineDAO had raised over $6 million in Ether.

While these numbers are nowhere near the amount of financial support the United States and European Union are expected to send to Ukraine, which could reach around $16 billion, they set a unique precedent of immediate, direct and horizontal support of a humanitarian cause — undoubtedly a tour de force by the global crypto community.

Regulatory anxieties

In addition to the widespread enthusiasm for immediate support of those in dire need, the conflict has reinvigorated the debate around the focal issue of international regulation: crypto’s potential capacity to subvert financial sanctions such as those imposed by the global community upon Russia. On March 2, at a hearing of the U.S. Congress’ House Financial Services Committee, California Representative Juan Vargas asked acting Federal Reserve Chair Jerome Powell if cryptocurrency could be a “way out” for financial transactions as Russia faced the possibility of being cut off from the global SWIFT network. Powell was not too specific in his response but went with the standard crypto-suspicious language:

“There isn’t in place the kind of regulatory framework that needs to be there. [...] What’s needed is a framework — in particular, ways to prevent these unbacked cryptocurrencies from serving as a vehicle for terrorist financing, just general criminal behavior, tax avoidance and the like.”

Simultaneously, a group of senators that include some consistent critics of the digital finance industry, such as Elizabeth Warren and Sherrod Brown, sent a letter to Treasury Secretary Janet Yellen expressing their concern. Pointing to the examples of North Korea and Iran, the authors shared their fears that crypto could be used to facilitate cross-border transactions to circumvent the new sanctions.

Strangely enough, among the various tools for such circumvention — such as the dark web and crypto wallets — the text underlined a possible “deployment of a digital ruble,” which has nothing to do with the global decentralized financial system.

Echoing U.S. regulatory anxieties, France’s finance minister, Bruno Le Maire, mentioned crypto during a speech on sanctions enforcement that very same day. He reassured the audience that the EU is “taking measures” against Russia’s potential moves to use cryptocurrencies, “which should not be used to circumvent the financial sanctions.” Le Maire’s points were largely restated by his German counterpart, Christian Lindner.

Earlier, on Feb. 25, European Central Bank President Christine Lagarde tied the success of preventing Russia from using crypto to dodge the sanctions with adopting the Markets in Crypto-Assets regulation legislation “as quickly as possible.”

The regulatory framework was scheduled for a vote in the European Parliament on Feb. 28, but it was postponed amid concerns that it would be misinterpreted as a ban on proof-of-work crypto mining.

Industry response

The industry was quick to respond to the widespread allegations, both rhetorically and through action. Both crypto publications and mainstream media published nuanced analyses of why Russia’s elites can’t effectively substitute access to SWIFT with crypto, putting forward several key reasons.

The first is the traceability of public ledger transactions, especially when it comes to enormous sums of digital money. Second, there is the issue of volatility and transaction fees, which are unlikely to please those seeking to turn around tens of millions or hundreds of millions of dollars.

After that comes the cash-out bottleneck: There are still few places in the world where one can withdraw huge sums of money unnoticed, and global law enforcers are aware of them. And, as experts say, an operation on the scale of a national economy would require amassing vast amounts of crypto, which is not a trivial task in a financial universe where money is mined, not printed.

Crypto’s current capacity to serve as a stealthy, fast, cheap tool for transferring big money from sanctioned jurisdictions elsewhere seems rather limited compared with that of the existing web of offshore infrastructure that has been sheltering wealth of any origin for the last 50 years.

The crypto industry at large has demonstrated conspicuous readiness to support the global effort to stop Russia’s actions in Ukraine and comply with existing Anti-Money Laundering and Know Your Customer standards. In a Twitter thread, Ripple CEO Brad Garlinghouse explained why it is almost impossible for established international crypto platforms to avoid sanctions: “In order to convert crypto to fiat, exchanges/etc rely on banking partners who could lose their licenses if someone on the OFAC list is able to slip through.”

This argument was echoed by Brian Armstrong of Coinbase, who also offered his take on Twitter and doubted that Russian oligarchs were using crypto to avoid sanctions.

It’s not just talk going down in Twitter threads — some major players are acting preemptively to facilitate the enforcement of the sanctions. On March 7, Coinbase published a blog post by its chief legal officer, Paul Grewal, in which he called for using cryptocurrencies to help ensure compliance with economic sanctions.

The platform reported it had blocked 25,000 wallets associated with Russian individuals or entities it believed to have engaged in illicit activity. Crypto exchanges Qmall, BTC-Alpha, CEX.IO and Bithumb have also frozen or terminated Russian accounts.

What’s next?

Discussing these recent developments with Cointelegraph, Ross Buckley, KPMG-KWM professor of disruptive innovation at the University of New South Wales, Sydney, shared a rather bleak vision of a global regulatory turn that will be heavily influenced by the war in Ukraine. In his opinion, nations imposing financial sanctions see any potential to circumvent sanctions as a reduction of their sovereignty:

“In my view, the Ukraine crisis and related sanctions pose a massive challenge to the crypto industry. If cryptocurrencies are used to evade sanctions, a strong regulatory crackdown should be expected. Sovereign nations are highly unlikely to tolerate the loss of capacity to impose sanctions.”

Haohan Xu, CEO of global digital asset trading network Apifiny, doesn’t rule out a scenario in which Russian elites indeed try to use digital assets as a global transaction tool alongside the more obvious options such as China’s state-owned UnionPay network. Speaking to Cointelegraph, he explained:

“The method of excluding Russia from participating in the U.S.-controlled global financial systems will force Russia to adopt other systems, which, naturally, will drive the growth of these systems that the U.S. does not control. [...] In this case, crypto would be legitimized in some parts of the world, and become a victim to hardline regulations from countries that are enemies of Russia.”

The endgame of the discussions between global regulators and the crypto industry would be defined by the latter’s willingness to give up more around anonymity and decentralization, which are vital parts of its DNA.

As Xu noted, “While most of the community is aligned behind the support for Ukraine, people are divided on the topic of major industry players rushing for compliance.” In contrast with Coinbase’s proactive approach and the reassurance of industry opinion leaders, some voices emphasized the necessity to stand by crypto’s core principles.

While this position may sound less convincing in the middle of a humanitarian crisis, the point is surely more understandable in the long run. “At issue is the broader argument of centralization and control versus decentralization and freedom,” argues Xu.

This presents a unique challenge for the crypto industry, Buckley believes, as its decentralization makes avoiding the hardline regulation scenario “almost impossible.” He is not convinced by arguments pointing to the traceability of decentralized assets, doubting that the new digital economy has many advantages over the established offshore system in terms of its transparency:

“In the absence of a centralized coordinator of the industry, I cannot see how cryptocurrencies as a whole won’t be used to circumvent the sanctions and thereby provoke a strong regulatory backlash.”

While Buckley believes that crypto can certainly be a force for good, he thinks it’s possible that Western powers will not see it that way if Russia successfully uses it to mitigate the effects of sanctions pressure.