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Weeks after designation, Iran’s sanctioned crypto exchanges became gold dealers Editor's Note: The underlying research and blockchain analysis in this article were originally published by Applied Technology Solutions (ATS), a Meridian3 joint venture partner, on September 14, 2026. (link) Between June and August 2026, the U.S. Treasury sanctioned Iran’s largest cryptocurrency exchanges. By Treasury’s own figures, they handled roughly three-quarters of the country’s digital-ass

Editor's Note: The underlying research and blockchain analysis in this article were originally published by Applied Technology Solutions (ATS), a Meridian3 joint venture partner, on September 8, 2026. (Link) What the Blockchain Does Not Show On-chain, Toobit’s exposure to Iran looks limited. Wallets attributed to the offshore cryptocurrency exchange show relatively little direct interaction with known Iranian exchanges. Viewed through blockchain analytics alone, an investigat

Editor's Note: The underlying research and blockchain analysis in this article were originally published by Applied Technology Solutions (ATS), a Meridian3 joint venture partner, on August 14, 2026. (link) We are revisiting the findings here in light of subsequent U.S. government actions that have significantly expanded sanctions pressure on Iran's digital-asset sector and the foreign entities that facilitate its access to global financial markets. On August 24, the U.S. Trea

Two wallets, ten million dollars, the same stablecoin. Everyone reads the numerator. The answer that matters is underneath it. I had a professor in graduate school with a thick Boston accent that reminded me of home. He taught macroeconomics, and whenever a formula came up he said the words with the full weight of that accent, the NUM-AH-RATE-AH over the DE-NOM-IN-NATAH. It stuck with me. These days, whenever I look at a stablecoin moving across the blockchain, I hear him. Ev

The United States built the premier tool for punishing grand corruption and human rights abuse. In 2025, it barely used it. So what is carrying the load now? The Global Magnitsky program is, in the State Department’s own words, the United States’ flagship tool for promoting accountability for human rights abuse and corruption. In 2025, according to the annual report submitted to Congress this past March, it was used to designate a net total of three foreign persons. For the f

Everyone watches the wallets and the exchanges. The infrastructure they all sit on top of has been hiding in plain sight. Over ten months in 2025, the U.S. Treasury sanctioned three bulletproof hosting providers in a row. Zservers came first, in February, in a joint action with the UK and Australia. Aeza Group followed on July 1. Media Land came in November, along with an expanded net around the Aeza network. In each case the target was not a ransomware crew, a scam ring, or

This month, at the 47th anniversary of the Sandinista revolution, Daniel Ortega declared that Nicaragua was finished with elections. “Never, never, never,” in his words. Whatever democratic pretense remained was gone. But a government that has dispensed with voters still needs revenue, and the Murillo-Ortega dictatorship has spent the past five years assembling a portfolio built around a single asset: sovereignty itself. Visa policy, mining concessions, border territory, and

On July 8, FATF said out loud what practitioners on both sides have known for years: nobody stops this alone. Whenever the subject of illicit finance comes up, it tends to look a lot like the famous Spider-Man meme, everybody pointing at everybody else. The private sector thinks governments should provide clearer guidance. Governments think the financial gatekeepers are not doing enough to keep bad actors off their platforms. Victims want more help from both. Blaming is easy.

Four Questions Every Sanctions Designation Should Immediately Raise Say a company has been “sanctioned” and most people picture a single, decisive event. A group of government officials sit around a table, a switch is flipped, and suddenly the name of a drug trafficker or terrorist financier appears on a screen with a large red X through it. In almost every case, the picture is wrong, or at least badly incomplete. “Sanctioned” is not a status. It is a shorthand that collapses

More than a thousand years ago, during China’s Tang dynasty, tax officials faced a practical problem. Moving coins across a vast country meant moving it along roads full of bandits. Their solution was simple but effective. A merchant deposited his money with an agent in one city and received a paper receipt. In another city, a second agent honored the receipt and paid out the equivalent. The coin never made the journey. Only the obligation did. They called it fei ch’ien, or “

Entity resolution is becoming one of the most important disciplines in financial intelligence. It is the unglamorous work of determining whether two records, two names, two companies, two passports point to the same underlying person or thing. Call it the Face/Off problem. Travolta and Cage made a whole movie out of how confusing it gets when the identity on the surface and the person underneath have been deliberately swapped. In financial crime, the swap can be done with pas

What happens when a crypto laundering network falls in the woods and no one is there to hear it? Last week, as G7 leaders gathered in France, the United Kingdom quietly added an entity in Nigeria to its sanctions list for supporting A7, the Kremlin-linked financial network behind the ruble-backed stablecoin A7A5. The designation marked the first time UK sanctions authorities had reached A7’s African expansion directly. To understand why a single Nigerian entity ended up on a

The flow is the easy part. The hand on the valve is the work. Last June, the U.S. Department of Justice unsealed a 22-count indictment against Iurii Gugnin, a Russian national living in Manhattan. Through his cryptocurrency payment company, Evita, he moved more than $530 million through the U.S. financial system on behalf of customers holding funds at sanctioned Russian banks, including Sberbank, VTB, and Tinkoff. The counterparties were scrubbed from more than 80 invoices. T

In eight days, two major jurisdictions executed large-scale exchange designations against two different adversaries. On May 26, 2026, the United Kingdom designated HTX, one of the largest cryptocurrency exchanges in the world, along with 17 other entities tied to Russian sanctions evasion. Eight days later, on June 2, the U.S. Treasury designated Nobitex, Iran’s largest crypto exchange, along with three other Iranian platforms and several of their executives. Two leading sanc

The enforcement question everyone is focused on is the wrong one. The harder problem is what comes next, in either direction. Last week, federal agents arrested a Cuban national in Miami who had been living quietly as a lawful permanent resident, managing Florida real estate through two U.S.-registered investment companies. Her sister is the executive president of GAESA, the Cuban military conglomerate designated under Executive Order 14404. When open-source research identifi

Illicit actors have always gravitated toward weak governance. What’s changed is what they’re able to build there. In testimony before the U.S.-China Economic and Security Review Commission this past March, Brookings scholar Vanda Felbab-Brown described something financial crime practitioners will recognize: enforcement that is selective by design, with entire sectors treated as too politically sensitive to regulate. She was describing Chinese criminal networks in Latin Americ

Much of the recent debate surrounding stablecoins in the United States has focused on regulation. The GENIUS Act, for example, centers on reserve backing, consumer protection, AML controls, and the integration of stablecoin issuers into the existing financial system. These are largely positive developments intended to bring stablecoin activity further within established regulatory and financial frameworks. At the same time, developments outside the United States suggest a bro

Recent reporting that Western Union has launched a Solana-based stablecoin (USDPT) reflects a broader shift in how cross-border value is settled. The significance is not the introduction of a new product; it is the convergence of infrastructure. For years, informal value transfer systems (IVTS), including hawalas and Chinese underground banking networks, have incorporated digital assets, particularly stablecoins, into their settlement processes. Cash is collected locally, and

Casinos have long been recognized as high-risk environments for money laundering. Large volumes of cash, rapid payouts, and the ability to move value through chips can make it difficult to determine the origin of funds. Even with strong compliance programs, tracing activity in these environments often depends on surveillance and the inherent challenges of dealing with highly cash-intensive activity. Cash remains one of the most anonymous payment methods available. Now compare

A Sri Lankan court recently warned that approximately USD 1 million may have been moved out of the country through cryptocurrency channels, highlighting a pattern that is becoming increasingly common in emerging markets facing currency pressure and capital controls. (Link to article: https://slguardian.org/sri-lanka-court-warns-of-crypto-smuggling-threat/ ) In jurisdictions where crypto remains largely unregulated but widely accessible, digital assets quickly become an inform