According to the indictment released by the U.S. Department of Justice (DOJ) on March 7, the arrest confirmation updated on March 13, and the statement from the Central Bureau of Investigation (CBI) of India, the Russian centralized cryptocurrency exchange Garantex has been forcibly shut down by a multinational joint law enforcement operation, and its co-founder Aleksej Besciokov has been arrested.

During this period, there has also been a large-scale freezing of funds associated with Garantex on-chain. This article aims to alert Web3 practitioners to the risks posed by USDT by outlining the details of the sanctions and freezes.

Background of Garantex Sanctions

Garantex is a Russian cryptocurrency exchange established in 2019, which has long been accused of providing money laundering services for illegal activities. In April 2022, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed sanctions on Garantex, stating that it had processed over $100 million in illegal transactions, including funds related to dark web markets, ransomware groups (such as Conti), hackers, and terrorism.

On March 7, 2025, the U.S. Department of Justice (DOJ) publicly announced the indictment of Aleksej Besciokov and his partner Aleksandr Mira Serda, accusing them of engaging in a money laundering conspiracy through Garantex, violating U.S. sanctions, and operating a money transmission business without a license.

It is alleged that Garantex has processed at least $96 billion in cryptocurrency transactions since its inception, including a significant amount of criminal proceeds. For example, U.S. authorities pointed out that the exchange had provided money laundering services for North Korean hacker groups (such as the Lazarus Group), Russian oligarchs, and several ransomware groups (such as Black Basta, Play, and Conti).

On-Chain Law Enforcement Activities

Coinciding with the arrests off-chain was a large-scale on-chain freezing operation, which was executed in collaboration with U.S. security firms and the USDT issuer Tether in response to the U.S. government's request. According to on-chain monitoring by Bitrace and Garantex's own disclosures on Telegram, the relevant law enforcement activities have frozen at least $28 million worth of USDT.

As early as when Garantex was sanctioned in 2022, the exchange began frequently changing its business addresses in an attempt to evade potential on-chain sanctions. However, this on-chain freezing activity was not directly targeting Garantex's operational hot wallet addresses but rather a large number of intermediary and hoarding addresses used to evade fund tracking. Before his arrest, Aleksej Besciokov or his team withdrew large amounts of funds from major cryptocurrency exchanges and payment platforms, and after highly automated fund laundering, transferred them back to other trading platforms.

Tether's law enforcement collaboration forcibly interrupted this process and directly led to Garantex ceasing its services.

The Threat of On-Chain Funds is Spreading

After researching the on-chain activities of all frozen addresses, it is not difficult to find that Garantex heavily utilized centralized entity addresses during its fund laundering process.

Taking the frozen Tron address TUCUYf as an example, the upstream source of funds for this address is a withdrawal hot wallet address from a payment or exchange platform, which transferred part of its funds to other centralized trading platforms before being frozen.

Another Tron address TXFUjf, before being frozen, not only interacted with exchange users but also had many connections with payment platforms and even online gambling platforms.

Clearly, beyond the on-chain freezing activities, such centralized institutions—if their operators conduct risk control on users receiving such funds for compliance reasons—will affect innocent OTC merchants or ordinary users receiving related cash-out funds.

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