Policy Scoop with Aislinn Keely: Legal and crypto exchange experts weigh in on how to navigate sanctions

Episode 24 of Season 4 of The Scoop was recorded remotely with The Block’s Aislinn Keely and Marco Santori, CLO at Kraken, Caroline Brown, former attorney at the U.S. Departments of Justice and the Treasury and current partner at Crowell & Moring, & Mark Wetjen, Head of Policy and Regulatory Strategy at FTX.US.

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In the weeks since the invasion of Ukraine, the US and others have levied heavy sanctions against Russia. Financial businesses, including crypto firms, are now expected to comply with regulations by blocking a growing number of sanctioned entities.

Some businesses, like PayPal and Revolut, have chosen to block Russian users altogether, despite this not being a requirement under the current sanctions regime.

Others, like Kraken, have made it clear that while they block all sanctioned entities, they will continue to serve Russian users until political forces definitively direct them to stop. And still others, like FTX, have chosen to cut off some Russian accounts that aren't on the sanction list in addition to the sanctioned entities but continue to serve most Russian users.

The varying approaches to sanctions compliance have left some wondering where the lines are, both legally and ethically.

Meanwhile, some lawmakers are floating proposals to empower the Treasury to bar crypto services providers from transacting with any addresses associated with Russia. 

In this week's episode of Policy Scoop, The Block's Aislinn Keely sits down with a sanctions expert and the legal chiefs from Kraken and FTX to parse out:

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  • What exchanges are responsible for when it comes to sanctions compliance.
  • The discussion surrounding blocking Russian entities that aren't sanctioned.
  • How crypto service providers are viewing current Congressional proposals.

This episode is brought to you by our sponsors FireblocksCoinbase Prime & Chainalysis
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About Chainalysis
Chainalysis is the blockchain data platform. We provide data, software, services, and research to government agencies, exchanges, financial institutions, and insurance and cybersecurity companies in over 60 countries. Our data powers investigation, compliance, and market intelligence software that has been used to solve some of the world’s most high-profile criminal cases and grow consumer access to cryptocurrency safely. Backed by Accel, Addition, Benchmark, Coatue, Paradigm, Ribbit, and other leading firms in venture capital, Chainalysis builds trust in blockchains to promote more financial freedom with less risk. For more information, visit www.chainalysis.com.


© 2023 The Block. All Rights Reserved. This article is provided for informational purposes only. It is not offered or intended to be used as legal, tax, investment, financial, or other advice.

About Author

Aislinn Keely is a reporter on The Block's policy team holding down the legal beat. She covers court decisions, bankruptcies, regulatory actions and other key moments in the legal sphere, putting them in context for the wider crypto industry. Before The Block, she lent her voice to the NPR affiliate WFUV and helmed Fordham University's student newspaper. Send tips or thoughts on all things policy and legal to [email protected] or follow her on Twitter for updates @AislinnKeely.