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.