OFAC Sanctions of SUEX and CHATEX Crypto Exchanges
November 10, 2021 - As of November 15, 2021, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned a second crypto exchange, Chatex, for providing 'material support' of SUEX crypto exchange in Russia for facilitating payments relating to REvil ransomware. For details tracing of Chatex addresses, follow this public Breadcrumbs report.
As a result of having received the sanction designation, all property and interests in property of the designated targets that are subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Additionally, any entities 50 percent or more owned by one or more designated persons are also blocked. In the case of Chatex, per the entity's website, one of the equity investors (presumably Egor Petukhovsky as he also founded SUEX) has been charged along with other related holdings he hold equity of.
The key takeaway with being sanctioned is that, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action.
For crypto-operators such as bitcoin ATM, payment facilitators, or virtual asset service providers such as exchanges, user transactions must be monitored to prevent the risk of interacting with any of these sanctioned addresses. This essentially require for these businesses to perform on-chain analysis before facilitating transfers of any users funds, and to prohibit any transfers into these sanctioned addresses.