• J Huang and S Pettigrove

EU extends Russian sanctions on crypto wallets and custody



Last week, the European Union issued a new wave of sanctions against Russia extending its prohibition on providing crypto wallet, account or custody services to Russians. The sanctions are a response to Russia's continuing military campaign against Ukraine and the Government's annexation of four Ukrainian regions.


Previously, the EU imposed a prohibition on providing crypto-asset wallet, account or custody services to Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia, if the total value of crypto-assets exceeds €10,000. The enhanced prohibition abandons the €10,000 threshold and expands the ban to all crypto-asset wallet, account and custody services.


The new restrictions do not distinguish between custodial and non-custodial wallet facilities and amount to an outright ban on providing crypto wallet and custody facilities in Russia and to Russian persons or entities. It is likely that wallet providers who are subject to EU sanctions will be required to geo-block Russia entirely as a consequence of the ban.


The sanctions package extends the geographical scope of the EU's trade sanctions with the occupied Ukrainian regions to Kherson and Zaporizhzhia. The package also includes additional restrictions on imports and exports of certain goods and technologies.


The United Kingdom has announced that it will also introduce further sanctions on Russia. The new UK restrictions include similar measures to the EU package but have not been published in full yet.


The United States has also announced new sanctions in response to Russia's annexation of the four Ukrainian regions. The latest package includes the designation of a large number of additional Russian entities and individuals as sanctioned persons and stepped up sanctions enforcement against those who provide material support to sanctioned Russian entities or individuals or sanctionable activity relating to Russia's military campaign and occupation of Ukraine.