Agent pays through a sanctioned exchange wallet

Agent pays through a sanctioned exchange wallet

Situation: An agent sends payment to a wallet that isn't on the SDN list directly. However, blockchain analytics reveals the wallet is a deposit address for Garantex — a designated Russian exchange. The agent doesn't know it's an exchange wallet.

Risk: Payment to a designated entity by any route is prohibited. The good-faith defense ("we didn't know it was a Garantex wallet") may not hold under strict liability. Wallet-only screening without analytics can miss this.

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