Welcome to season 3 of the Public Key podcast! New Season, New Hosts, New Look. The Crypto Crime Report is almost on newsstands and this week we feature our own national security and intelligence experts at Chainalysis, Eitan Danon (Content Marketing Manager) and Andrew Fierman (Head of National Security Intelligence). The duo talks about crypto sanctions evasion, emerging networks and alliances among nations like Russia, Iran, North Korea and China and the rise of crypto services including Huione Guarantee and Russian Instant Exchangers.
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Public Key Episode 151: Crypto and Geopolitics: Unmasking Sanctions Evasion Tactics
With the Chainalysis 2025 Crypto Crime Report about to be released and the news about Bybit and the largest crypto hack in history, there is no better time than to discuss DPRK, sanctions evasion and the rise of crypto services used by illicit actors, including Huione Guarantee and Russian Instant Exchangers.
In this episode, we feature our own national security and intelligence experts at Chainalysis, Eitan Danon (Content Marketing Manager) and Andrew Fierman (Head of National Security Intelligence).
The duo acknowledges the emerging networks and alliances among nations like Russia, Iran, North Korea and China and how blockchain technology is transforming sanctions enforcement, citing examples like Hamas and North Korea.
The conversation also highlights Russia’s legislative changes and cross-border transactions, while placing an important awareness of professionalization in the crypto crime ecosystem and the national security risks that the entire ecosystem faces.
Quote of the episode
”Hundreds of millions of dollars a year are being processed through these types of instant exchangers. That allows anybody to transact on your platform, doesn’t require any KYC information. And what you can do is you can either swap crypto for crypto, but you can also, in a lot of these Russian language instant exchange services, on or off ramp your sanctioned Russian bank money.” – Andrew Fierman, Head of National Security Intelligence, Chainalysis
Minute-by-minute episode breakdown
2 | Sanctions and crypto and how to navigate geopolitical challenges
8 | Hamas and Al Qassam brigades use crypto donations for terrorist financing
11 | Emergence of Russian Instant Exchangers and Russian bank sanctions evasion
13 | Understanding “Secondary Sanctions” and how they apply to crypto
19 | Crypto networks and alliances forming amongst Russia, Iran, North Korea and China
23 | How Iran and Russia are using crypto to move conduct crypto cross border payments
27 | Southeast Asia and the surge of crypto crime and pig butchering schemes
29 | Exposing the Huione Guarantee service provider and why they are at the heart of the massive crypto crime ecosystem
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Speakers on today’s episode
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Transcript
Eitan
Welcome to public key. I’m Eitan Danon, and I’m here today with Andrew Fierman, the head of national security intelligence at chainalysis. I should say, welcome back to the show. Andrew. Hey, Eitan, how’s it going great to have you on this is your second time on the show. Looking forward to our discussion. Yeah, thanks for having me, let’s let’s hop right to it. So we are in the in the midst of our 2025, crypto crime report. And as many of our listeners know, we’ve been pre releasing sections starting in December, but all through January and February, and full report is going to come out in a matter of weeks. I want to talk to you today about a lot of the geopolitical centric aspects of the report. And I want to hop right into kind of my first question for you, which is about sanctions, very much your bread and butter you have, in addition to focusing on national security chain analysis, you have worked at a number of large international banks. So my first question for you is, what do sanctions look like in the crypto ecosystem? And could you walk our listeners through the difference between sanctions on chain and sanctions in this in the tradfi space? Yeah.
Andrew
When I got to chain analysis first, I started to quickly realize how valuable the information on the blockchain is especially when it comes to monitoring and managing sanctions risk. So kind of a little bit of backdrop in traditional finance, you get an entity that’s put on the OFAC SDN list, and then it’s your responsibility to screen any transactions with them. But also there’s this aspect called the 50% rule, which means that you’re responsible for monitoring and blocking activity with any entities that are 50% or more greater owned by that same entity. The problem being is that those entities aren’t necessarily always included on the SDN list. They’re not even necessarily even created yet at that time. So they may be, you know, a follow on activity by that entity after their designation. But then that requires a lot of secondary tooling. You have to continue monitoring a lot of different places, vendor tools, as well as, you know, public registries, to ensure that you are capturing any entity that may be 50% or more owned or controlled by that entity. Now enter cryptocurrency, and we’ve got on Bitcoin, the utxo model on Ethereum and Tron and other account based assets. You have that model, and in those instances, there’s a great opportunity to expand on the coverage of those entities nearly instantaneously. So for example, we’ve seen a bunch of sanctions on larger entities over the last few years, and take guarantees as one. They had three cryptocurrency addresses, two Bitcoin addresses, one Ethereum address, included in the designation itself. But with the opportunity of having blockchain analytics behind it, we have millions of addresses that belong to them that you’re instantly able to monitor for similarly, the same thing with hydro, which is a dark net market sanctioned at the same time as guarantees actually and 117 addresses included in that designation, and over 6 million addresses being covered within blockchain analytics for chain analysis. So there’s this great opportunity that’s presented, especially when you have entities that are, you know, services utilizing cryptocurrency at scale. So whether it be a mixer or or a cryptocurrency exchange that’s been put on the SDN list, it presents a really great opportunity, pretty quickly, taking a step back, though, I think it’s been a really fascinating development when it comes to the involvement of cryptocurrency in sanctions. So Rewinding back to 2018 was the first time a cryptocurrency addresses was included in an OFAC designation, and it was actually two addresses belonging to two Iranian nationals affiliated with the IRGC Sam ransomware, right? Exactly, facilitating ransomware payments. So in those instances, you know, there may be a few extra addresses involved with them based on that utxo model, which involves co spend and change, which are some more complex things when you’re talking about cryptocurrency, but maybe a conversation for later. But what we really start to see over time is this development that it’s not just cyber actors like ransomware actors or individual North Korean hackers or, in some instances, fentanyl traffickers with just a few addresses here and there. You know, in 2020 2021, OFAC sanctioned suic, which was an over the counter Russian exchange. Processing over $160 million for ransomware and a lot of other illicit activities. And then, like I mentioned just before, in 2022 that’s when things really started to roll in. And you see two different mixers get sanctioned, including tornado cash, which obviously we know all about, and then additionally guarantees Hydra and a whole host of other actors. So what that tells me is that this ecosystem has really expanded to include cryptocurrency as an identifier in sanctions designations, not just in cyber related activities, but across all criminal aspects of of the ecosystem.
Eitan
So the transparency of the blockchain there is really unlocking things that perhaps wouldn’t be impossible, but would be much more difficult to accomplish in track five. Would do you think it’s fair to say to say that?
Andrew
Yeah, absolutely. I mean, it’s not easy tracking shell companies when you have entities like nation state actors using law firms and and corporate registries and jurisdictions that are are not friendly to identifying who’s actually behind them, whereas here on the blockchain, we can see everything you know, the transparent. It’s immutable, that information is forever there to identify and build on great
Eitan
well, you touched just now on a number of sanctioned jurisdictions and entities. I wanted to transition slightly so we have seen actors and networks that have been heavily targeted, from Hamas to North Korea and everything in between, driven outside of traditional payment rails and to the periphery of the international finance and financial system and outside it. How are you seeing these actors use cryptocurrency, and how do you and your team approach these actors trade craft on chain, their priorities, and how they kind of have evolved their own, you know, the way that they that they are engaging with the financial system,
Andrew
that’s been another fascinating thing as I continue to monitor this ecosystem. And I think one thing to really understand is, like bad actors are going to find ways to launder their money or move their money. It’s not just a cryptocurrency issue, it’s a opportunity issue. And so these types of actors that you know we’re talking about here would do the same thing in traditional finance or any other aspect of laundering money that they have the capacity to do so. So when it comes to cryptocurrency, you know the use of blockchain analytics once an entity is identified, or their wallets are identified in tools like chain analysis, any compliant exchange or operator in the ecosystem that’s utilizing this technology is going to stop doing business with them, so they quickly can become aware that it’s likely that their information is now residing in blockchain analytics tools, and therefore they have to get more creative. So we saw this very early on with Hamas and Al Qassam brigades, as they had a donation campaign in cryptocurrency with just a single bitcoin wallet. And then they ultimately evolved, over time to utilizing a single use wallet, so producing a brand new wallet for every potential donor. And if funds weren’t sent to that wallet, then the wallet never gets created. It never gets on the blockchain. So unless you’re actually making that transaction to Al Kasam brigades, you weren’t going to be able to identify their on chain infrastructure that being said, because of the transparency of the blockchain, they ultimately announced that they were just going to stop doing cryptocurrency donations, writ large, because of the fact that their donors were getting prosecuted. So when you’re talking about donation campaigns, terrorist organizations, a lot of that is more grassroots. It’s going to be online, whether from their website or on social media. They’re going to post some addresses. And really the you know, the challenge for them there is that they have to have these donations public in order to be able to get their users support. And so when it’s not public, they’re not going to get as much donations, and in reality, that also presents a very easy opportunity to track and monitor on an ongoing basis. We saw one individual by the name Fauci, who’s a member of Hayat Tahrir Al Sham. He was sanctioned by OFAC in 2021 and in that designation, they specifically said one of his really big focuses was soliciting donations for motorbikes for the Mujahideen, and he did it on social media. So once we’re able to identify his social media page, of course, he’s still soliciting donations to this day, but you know, every time he does, he’s posting it publicly, so it’s sitting there for anyone to. Take a look at. So from a donation campaign perspective, I think it’s a fairly straightforward approach. From our team’s perspective of monitoring it. When it comes to the larger, more complex actors, that’s certainly where things can become more challenging. They can change around their infrastructure and attempt to avoid detection. So certainly, we’re continuing to monitor all of those groups on a regular basis as well for them to kind of divert their approach to try to evade our detection. That being said, you know, I have a team of wonderful intelligence analysts who are monitoring this ecosystem, day in and day out, whether it be Russia, Iran, if you know, things change in Syria, like happened with haya Tara Al Sham just a few months back. Or you know, Venezuela makes new announcements where we’re watching the entire ecosystem and looking to identify the activity that’s happening on Qing
Eitan
Awesome. Well, you mentioned evasion, which I have to ask given current geopolitical tensions. I mean, we had the full scale invasion of Ukraine in 2022 we had October 7 and the aftermath and kind of everything that ensued in the region. And we’ve had multiple rounds in the middle east of Iran, Iran centric activity, not only as pertains its its nuclear program, but also its ties to regional proxies, given you know, in the US and globally to given the prominence of sanctions in the foreign policy toolkit, do you think, from your vantage point, That crypto is going to play a more or less significant role in evading sanctions or kind of neutral. How do you see that fitting into the sanctions evasion puzzle, given that policymakers often report revert to sanctions, it’s you know, in air quotes, no one is hurt immediately, you can show that something is being done. You’re not dropping ordinance on anything, although you could, you know, you could argue that it’s economic ordinance and that it’s not an effect free policy. But how do you kind of put all of those puzzle pieces together from your perch?
Andrew
Yeah, it’s, it’s, it’s challenging. I mean, listen, you know, once you’ve been shut off from the US financial ecosystem, then there is often an effort to try to get around it. I mean, certainly utilizing the US dollar is the preeminent currency for any transactions in the world, and so especially taking a case like Russia, where almost all major banks have been sanctioned, and not just sanctioned, by the way, but subject to secondary sanctions. And a quick note for the listeners here on that
Eitan
down, yeah, I know secondary sanctions, but I think for folks who are not familiar, yeah.
Andrew
So essentially, you know, there’s the OFAC SDN list, which means any entity that’s on that list, can’t do business with, but when secondary sanctions are applied to those entities, essentially what that means is that if you do any activity with those entities, you too could be subject to sanctions for just interacting and to what extent you have to engage with them to be sanctioned. It’s a little bit open ended. It’s significant transactions. So, you know, it could be one really large transaction. It could be ongoing, committed transactions. But essentially, it exposes this new risk that a lot of countries don’t want to take. And so when you’re talking about a dynamic like, say, Russia and China, there was a lot of warming up between the two nations shortly after the start of the war, but once those secondary sanctions got applied, we saw a lot of cooling and heard a lot about cooling publicly, which is, you know, China says, Hey, listen, we want to do business, but we don’t want to get sanctioned for doing business with you. So I think that changes things to some extent. But going back to your question around you know, cryptocurrencies role in all of this is, when you are pushed away from the US dollar, those actors will always tend to identify the best possible approaches to get around that right? And so whether in traditional finance, it’s using third party proxies or shell companies to facilitate your business activities and mask you know where you’re where or who you are, or it’s using things like stable coins that may be a better effective tool to managing it. But again, realistically, you know, if you have compliant exchanges operating in the at a global scale, in the ecosystem, managing that risk and conducting their sanctions screening and using Blockchain analytics, using things like IP blocking to ensure that people aren’t logging on. Jurisdictions they’re not allowed to then there’s a great opportunity to restrict the on and off ramping of activity with, you know, nation states or jurisdictions or entities that are subject to sanction.
Eitan
So I want to probe just a little it was said after the invasion of Ukraine, the second round, you know, after Crimea one, you know, in 2022 Russia could not evade sanctions on chain. At scale, you can’t run a g20 economy on the blockchain for a host of reasons. And we at chainalysis actually put a great blog out about that. I encourage our listeners to go check it out. However, dot, dot, dot. Can you finish that sentence? What can Russia do on chain? Certainly project power. How would you, how would you finish that sentence?
Andrew
That’s a long sentence to finish. But no, I think you know, we’ve seen ways that it’s been done, but in addition to that which, and I can talk about that, but in addition, I think, hypothetically there, there are ways that Russia would look to do it, and so that can happen in a handful of ways, one of which being, we saw legislation late last year in Russia permitting cross border transactions to be conducted via cryptocurrency. So that’s certainly one angle. You have Russian companies that are, you know, generating new addresses and obtaining, you know, crypto liquidity from a mainstream exchange, maybe through, you know, a friend in another country, or someone who’s not going to raise a red flag when, you know, getting sent a lot of money and then conduct their business internationally via whatever the currency is they’re choosing to use. And so with that permissibility in country, I think that probably gives Russian companies a little bit more of an empowered interest in being able to utilize cryptocurrency to facilitate those transactions that, again, they’re not going to be able to do in the traditional financial space, because of all of the Russian banks being sanctioned to facilitate that. So with that said, you know, I think the challenge for them still comes to the point of on and off, ramping that activity. There needs to be enough liquidity at exchanges to facilitate that on and off, ramping at scale. And when we’re talking about scale, we’re talking, you know, economy wide, hundreds of billions of dollars type scale here. But what we are definitely seeing is, is this development of Russian language instant exchange platforms. And essentially what these do is the, it’s a it’s a platform that you can get built for $5,000 or so with some infrastructure that allows anybody to transact on your platform doesn’t require any KYC information. No, no. You know, real information is required to be provided. And what you can do is you can either swap crypto for crypto, so you can go take Bitcoin and move it to Ethereum. But you can also in a lot of these Russian language instant exchange services, on or off ramp your sanctioned Russian bank money. So essentially, the way this works, you log onto the site, you click that you have money at sanctioned Russian bank A and you attach your bank account at that bank, you transfer rubles over to the instant exchange, and you give a cryptocurrency address that you’d like them to send the crypto equivalent of the amount of rubles you’ve sent in then on chain, where it becomes challenging is that all you’re seeing is a transfer to a wallet from one of these Russian instant exchanges from, you know, in whatever cryptocurrency it is, you’re not seeing the off ramp or the on ramp side of it, which is the sanctioned Russian bank having been used to facilitate that activity. And maybe a teaser for our upcoming crime report. But you know, we see, you know, hundreds of millions of dollars a year being processed through these types of instant exchangers and so. So while this is not at scale, it’s certainly not an insignificant number. Great.
Eitan
I mean, it certainly sounds like to make sure I’m understanding, you know, why you can’t run the entire economy. There’s a lot you can do still to move funds around. And you know, not only between the central bank esque kind of players, but larger, larger denominations than just a retail user. Is that right?
Andrew
Yeah, and we’ve actually seen this as a result of some of the interesting sanctions that have happened this year involving Russia. One that comes top of mind to me was an entity by the name KB Vostok, and it’s a Russian drone manufacturer that sells a drone that costs, you know, give or take, 2000 USD for each drone. And. And they explicitly state on their own website that their job is to create drones to service the Russian military economy, right? So if you can imagine who might be paying a company like that, my best guess would be that it’s likely you know Russia safe to say, safe to say, right? And while this drone operator only, you know, had received a total of $40,000 most of those transactions were in you’d guess it surprised denominations of roughly $2,000 and when you look at the wallet that’s sending funds to them, that wallet has $40 million that it’s processed. Now we’re talking about someone a little bit more significant in scale, in an operation that is operating on the blockchain has a lot of exposure to guarantees, which, again, sanctioned Russian crypto exchange. So certainly, it has the hallmarks of being, you know, potential Russian military activity. And it gives, it gives a bit of a line of sight to what that might look like in reality. Great. Well,
Eitan
I want to, I want to weave a few of those things together now. And you know, the Iranians, according to press reporting, the Iranians are have built a drone manufacturing operation inside Russia, inside tataristan and Russia, the North Koreans have sent soldiers to Ukraine, to the front lines, to support the Russian war effort. And even in our stolen funds section, which was pre released in December, there’s an interesting geopolitical angle, whereby, after Putin visited North Korea, Pyongyang over the summer, there was a change in on chain inflows and in transactional activities. So the off chain connections between China, Russia, North Korea, Iran and allied countries, it has been and is being covered extensively in press. I’m hoping for our listeners who are interested in this topic, can you give a little taste of how these regimes and powers are interacting with each other on chain. Certainly, the efforts of the BRICS is one part of the story. But what are the kinds of examples that you see day in, day out, and what do you think it means?
Andrew
I think there’s still a lot of positioning that’s going on while it is, I’m sure, happening in reality. There’s, you know, ideas being floated by Iran of a gold backed stable coin, and then, like you mentioned, you know, a BRICS affiliated currency. And you know, obviously a lot of these countries have the same problem in common, which is restrictions from the US dollar. And so, you know, they’re looking to form an opportunity to be able to facilitate that activity, sans the US dollar, of course. And one thing that we are seeing is the use of dual use goods and dual use equipment, which I think is a really fascinating aspect, and not necessarily even dual use goods, but also things like mining equipment, coming from, you know, cryptocurrency mining equipment, cryptocurrency mining, yes, not traditional coal mining, which is another economy in Russia and North Korea, but certainly not one for this conversation. But you know, when you’re talking about, you know, mining equipment, or cryptocurrency mining equipment coming from, you know, manufacturers or resellers located in places like Hong Kong or in China, and when you’re seeing on chain, the exposure to these types of entities are, you know, to an extent touching an Iranian service or Russian service, that seems to indicate that there’s likely some purchases going on, you know, between those, those, those jurisdictions and so that is something that has been top of mind, also things like drone resales. I mean, certainly, you know, a commercial drone is totally a permissible thing to sell, but if you’re selling it in bulk, and it’s ending up in the hands of Russian entities, particularly wallets like the one I spoke about with kB Vostok counterpart, that may be a little bit more interesting, but I think in reality, when you’re talking about nation state actors, their operational security and in facilitating transactions is going to be better than, say, your terrorist organization that’s posting a cryptocurrency address on social media. And so, you know, when we think about it, it’s probably fairly likely to say that they won’t be using mainstream Iranian exchanges and mainstream Russian exchanges to conduct that type of activity. They’re going to be using more obfuscated techniques in order to facilitate what they’re doing. And certainly an example. Example that kind of highlights this effort was in December, a IRGC affiliated Houthi financier had been sanctioned. Well, had been sanctioned a few years ago by ok
Eitan
Saeed Al Jamal. For those who are Iran watchers, an Iran based facilitator, we actually put a blog out about this, but I would love for you to spell out the network for our listeners. Andrew, yeah,
Andrew
I mean, listen. Long story short, you know, when he had his sanctions designation updated, there were cryptocurrency addresses included, and that was the update. And when we go look at those cryptocurrency addresses on chain, you’re seeing someone who, you know, processed, you know, in and outbound, a total of roughly $300 million I mean, so that’s a pretty significant amount of funds. And kind of to the point I was trying to make before is, you’re not seeing those funds originating from an Iranian exchange and ending up in, you know, a Yemeni exchange, right? We’re not, we’re not seeing this like very clear statecraft coming from the source of the largest mainstream exchanges in any jurisdiction. This is being done through complex networks where they’re facilitating movement of money, obfuscating the sources intentionally. I mean, this is, this is what the IRGC, what Hezbollah, is known for doing in traditional finances for decades. So this is nothing new. It’s just a different mechanism in which it’s being done. Awesome
Eitan
well beyond, you know, kind of the big four, whatever you want to call them. There’s a lot of nomenclature in policymaker. Kind of space. Can you walk our listeners through, kind of, some other geopolitical issues with the crypto Nexus? I know some folks at chainalysis worked on a report with it, with a big think tank in DC on crypto in Venezuela. We’ve looked at use cases in Sub Saharan Africa that are not necessarily front and center in conversations around great power competition, but what are? What are some of the other kind of dynamics that you see, either on the money laundering front, or more broadly, as it relates to geopolitical conversations,
Andrew
I think I want to kind of take this towards Southeast Asia, particularly Cambodia, Myanmar, where there’s, I wouldn’t even say it’s emerging. It’s really already here is a massive scam ecosystem, and we’ve touched on it before. We’ll be touching on it more in this year’s crime report, but we won guarantee really being at the at the front and center of that. And for those of you who haven’t heard about it yet, it’s essentially this online entity that offers escrow and dispute services for anyone utilizing the service. So Disney World for pig butchering, yeah, yeah, it is. You can, you can. You can post an advertisement of whatever it is you have available for sale, whether it be a service or a good, and then you can leverage the guarantee platform to facilitate those transactions. And so far, we won guarantee. Since the start of COVID has been responsible for processing over $70 billion now is all of that scam technology or all of that money laundering, probably not. But what we have seen are scam technology vendors, so people who are selling everything from PII data to AI voice and facial recognition software for fairly low amounts of money, which then allows a pretty low bar or low barrier to entry for anyone who’s looking to get involved in pig butchering or investment scams. And so when you’re talking about a network at that size, it becomes a pretty significant focus when you’re talking about the national security sphere, more more broadly than that, the Big Four, however we want to brand it
Eitan
great. Well, I want to, I have a few more questions for you that are more future oriented, looking out for the year ahead. What are you keeping an eye on most closely, on chain, off chain, otherwise, or kind of how tradfi and crypto blend together, and how you can collect and analyze things. What are some of the trends that are that you’re looking forward to keeping, keeping your, you know, keeping your eyes on,
Andrew
I think, taking a look at how the legislation from Russia last year really pans out in reality, what do these cross border transfers look like on chain at scale, what will happen with the other part of that legislation, which was to facilitate crypto mining in the country? And like, to what extent is that happening, and how is it being facilitated, whether it be through the equipment providers in other countries? Yeah, and then a lot of what we’ve just touched on, which is what are the relationships going to look like between Russia, China and also Iran. But I think also, obviously, with the new administration, the focus on China is going to be really an important aspect of monitoring what’s going on in the ecosystem. And I think China has been pretty mercurial at best, with how they’ve existed. From a cryptocurrency perspective, it’s a
Eitan
very diplomatic characterization.
Andrew
Yeah, so I think you know, just really trying to keep monitoring what’s going to be happening in those regions is top of mind.
Eitan
Great. And for those listeners who missed it, we put a blog out called legislated sanctions invasion in the fall that dives deeply into Russia’s pivot on crypto writ large, the finance ministry, central bank and and power centers in Russia. Give it a read. I think I know what you’re going to say, Andrew, given you’re a sanctions guru. And you know, you were just teaching our listeners about we want guarantee the we want ecosystem. But, you know, certainly in this year’s crime report, we have written a lot about the diversification and professionalization of the ecosystem beyond, you know, if you can call it that your mother’s crypto crime, what, where would you steer our listeners? What are some of the more compelling putting sanctions and scams aside for a second, you know, what’s another section or what’s another story that you would recommend our listeners dive into?
Andrew
I’m really excited, because this year, we are going to be releasing an organized crime section for the first time. And I think to your point, that really will start to highlight how, you know, cryptocurrency is not just being used by cyber criminals, and not only that, it’s, you know, it’s being used by all illicit actors, but there’s now a professionalization of it, and that’s something we’re going to dive into and how that’s being done. So I don’t think that section’s out yet, so bear with us, but excited to see that one come out.
Eitan
Terrific. Well, thank you for the awesome conversation. And yeah, appreciate it.
Andrew
Thanks for having me a ton. Yeah, forward to talking to you soon. Yep, bye.