TRM Labs indicates that the sanctioned cryptocurrency exchange Garantex Europe may have long had contingency plans in place to circumvent U.S. measures.
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned Garantex and its successor Grinex for the second time on Thursday.
However, a report released by TRM Labs on Thursday pointed out that the sanctions may be difficult to enforce, as institutions like Garantex "often prepare in advance for anticipated enforcement," allowing them to quickly relocate customers, related facilities, and funds to successor platforms.
Garantex has been a significant channel for money laundering, dark web market transactions, and other illegal financial flows. OFAC estimates that the platform processed billions of dollars in cryptocurrency transactions between 2019 and March 2025.
Authorities in the U.S., Germany, and Finland seized Garantex's related facilities in March, but TRM Labs noted that records from the Kyrgyzstan government show Grinex was registered in December 2024 to take over related operations at any time.
TRM Labs stated that wallets associated with Garantex began transferring funds into the ruble-pegged stablecoin A7A5 starting in January 2025, weeks before the seizure actions, "highlighting their anticipation of enforcement actions and intent to establish a value transfer channel resistant to sanctions."
It is estimated that Garantex processed over $100 million in illegal transactions before OFAC's first sanctions in 2022, and subsequently handled hundreds of millions of dollars in funds.
"The multinational seizure actions in March 2025 failed to stop related activities. Instead, Garantex's management quickly initiated a contingency plan that had been in preparation for months," TRM Labs stated.
TRM Labs noted that another cryptocurrency exchange, Meer, is one of the first platforms to launch the A7A5 stablecoin, with functionalities and trading interfaces similar to Garantex and Grinex.
The website was also registered in December 2024, close in timing to Grinex and A7A5.
TRM Labs pointed out that this timing reflects a coordinated effort, as Meer saw a surge in trading volume after Garantex was seized in March 2025, indicating it may serve as an additional channel for maintaining cash flow and is related to the network's illegal financial activities.
After Garantex was seized, the introduction of the A7A5 token became a key link in the transition from Garantex to Grinex, facilitating the circulation and subsequent recovery of frozen customer funds.
TRM Labs noted that the Garantex–Grinex–A7A5 connection is a "typical case" for monitoring the transfer of illegal activities and should prompt stricter due diligence on opaque stablecoins.
The company added, "This case further illustrates that while stablecoins are often promoted as tools for conventional settlement or compensation, they can become a core component of sanctions evasion strategies when associated with opaque corporate networks and sanctioned financial institutions."
Related: Reports indicate that Vietnamese police have uncovered a multi-billion dollar cryptocurrency Ponzi scheme behind Paynet Coin.
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