Enhancing the EU Response to Crypto-Enabled Sanctions Circumvention

22 Jun 2026 12:23 PM

To disrupt Russia’s sanctions-evasion networks, the EU must target the infrastructure that allows for widespread use of crypto: liquidity, convertibility and access to the formal economy.

Crypto is no longer a peripheral feature of sanctions evasion. Nor is it a self-contained world of wallets, tokens and exchanges that can be addressed separately from the wider architecture of illicit finance. For Russia, Iran and other sanctioned actors, crypto-assets are increasingly embedded in broader systems of procurement, payment, settlement and value transfer. They are used alongside the traditional suite of tools favoured by sanctions evaders, including shell companies, trade-based evasion, third-country intermediaries, money service businesses and professional enablers.

The EU has already begun to recognise this. Recent Russia sanctions packages have included measures targeting crypto-assets, crypto-service providers and Russia-linked instruments such as A7A5. And recent proposals for a 21st Russia sanctions package suggest that this trajectory is continuing, with the European Commission signalling further action against crypto platforms and, for the first time, the possibility of a full third-country ban for crypto-asset services linked to Russia’s circumvention activity. But the direction of travel, while welcome, does not remove the need for a more operationally focused strategy.

But the challenge is moving faster than the policy response. Russia’s networks adapt quickly, exploit gaps between jurisdictions, and combine traditional and digital finance in ways that are difficult to capture through entity-by-entity designation alone.

The next phase of the EU response should therefore be built around a simple proposition: crypto-enabled sanctions circumvention is an infrastructure challenge. The task is not merely to identify which sanctioned actor used which wallet. It is to understand, target and disrupt the infrastructure that allows sanctioned actors to turn crypto into usable financial power.

Against this background, in early June, the Centre for Finance and Security at RUSI convened a roundtable discussion of EU and UK policymakers and crypto experts at RUSI Europe in Brussels to consider what steps the EU could take next and what lessons can be learned from recent crypto sanctions actions by the UK.

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