Cryptocurrency isn’t the primary threat to sanctions enforcement

Authoritarian states may not be may not be that interested in payments networks they can’t control

The effect of cryptocurrency technology on the U.S.’s ability to enforce sanctions is a topic that has been receiving more and more government attention. Mostly it has been a reaction to Venezuela’s attempt to create an oil-backed token called the Petro. This scheme has led the White House to issue an executive order, and Congress to consider a bill codifying that order. The Treasury department also recently issued guidance emphasizing the sanctions obligations of digital currency intermediaries with regard to the sanctions on Iran.

The use of cryptocurrency to evade sanctions has dangerous potential that should be taken very seriously. That said, the real risk to sanctions enforcement comes not from technology, but from an escalating challenge to the U.S.-dominated international payments system. According to a insightful recent article by Yaya Fanusie, a former CIA analyst, and director of analysis at the Center on Sanctions and Illicit Finance at the Foundation for Defense of Democracies,

[T]he greatest sanctions risk is a long term one; that nation-states that desire to displace the U.S. dollar as a global trading currency might do so slowly, by creating a functioning parallel value-transfer system that does not move U.S. dollars or go through New York City. This would be an alternative to the SWIFT infrastructure that is essential to transferring funds today. Such a system would not respond to the current sanctions enforcement playbook.

In effect, the threat to the U.S.’s ability to enforce sanctions comes not from blockchain technology, but from the desire to end the U.S.’s dominance of international payments and settlement. Even European states like France, Germany, and the UK have agreed to work with Russia and China to develop a payments system that routes around U.S. sanctions on Iran. Given such a drive, what technology they choose to use is a secondary question. But if it’s a SWIFT-like international settlement system that’s the goal, a permissioned blockchain consortium of dissenting states might be the more serious threat, not a public cryptocurrency network like Bitcoin. (For the distinction, see here.) As Fanusie writes,

Sanctions evasion using cryptocurrencies is not likely to be a major threat for the short term. In the long run however, if a reliable blockchain-based system emerges that can support financial transactions on par with the SWIFT system, U.S. sanctions power could be diminished. Still, a true “blockchain SWIFT” is something that probably would take decades to unfold.

And as Fanusie’s article notes, the more serious state-level explorations into blockchain technology to evade sanctions are not focused on public-network cryptocurrency technology, but on using permissioned blockchains for trade settlement. Both Iran and Russia have conducted pilots using Hyperledger Fabric to create permissioned ledgers. In contrast, Venezuela’s Petro, which would rely on a public network, is widely understood by experts to be an incompetent effort.

That should not be surprising. It stands to reason that authoritarian states like Russia, Iran, and China would want to have the kind of control that permissioned blockchains afford. Bitcoin has often been called a “stateless” currency, which should be a much more concerning proposition to strong states, than to liberal countries that thrive on permissionless innovation.


Based in Washington, D.C., Coin Center is the leading non-profit research and advocacy center focused on the public policy issues facing cryptocurrency and decentralized computing technologies like Bitcoin and Ethereum. Our mission is to build a better understanding of these technologies and to promote a regulatory climate that preserves the freedom to innovate using permissionless blockchain technologies.