Trump-proofing Canada means ending our dependence on SWIFT

It's time to stop staring into the headlights and respond to the fact that Canada is being eyed as a choice morsel by a much larger predator: our former ally the United States of America. In President Trump's very own words, he wants to use "economic force" to join Canada and the United States together. In anticipation of the U.S. turning its economic might against us, we need to locate all the ways in which our access points to various crucial financial networks are controlled by this predator, and switch those dependencies off, quickly, before they are used to hurt us. One of our most glaring dependencies is the SWIFT network.

Banking and payments run on networks. And network users tend to coalesce around a single dominant network, like SWIFT or the Visa and MasterCard networks. Which leaves whomever controls the dominant network, often the U.S, with tremendous power over all the network's other users. If Canada can reduce our exposure to some of these networks now, then we can't be exploited by the Trump regime down the road to weaken us economically, sap our strength, and threaten to take our resources or annex us.

I've already written about one point of failure: our dependency on the U.S.-controlled MasterCard and Visa card networks. Canada has enjoyed huge conveniences by being connected to the U.S. card networks. However, if Trump were to suddenly cut off our access, Canadian credit cards would be rendered ineffective in one stroke, throwing us into chaos.

The good news, I wrote back then, is that our MasterCard/Visa dependency can be solved by building a domestic credit card system, underpinned by Interac, our made-in-Canada interbank debit network. With a domestic fall-back in place, the threat of a Trump disconnection would no longer loom over our heads. Canada wouldn't be doing anything unique. All sorts of nations have their own indigenous credit card systems, including India, Indonesia, Brazil, France, and Japan.

The next chokepoint we need to address, and quickly, is Canada's dependence on the SWIFT network. Most Canadians don’t realize that SWIFT isn't just an international payment tool. It is deeply embedded in our domestic financial system, too.

What is the SWIFT network? Payments are really just synchronized updates of bank databases. A paying bank subtracts numbers from its database while the receiving bank credits its own. To initiate these updates, banks need to communicate with each other, which is where SWIFT comes in. Think of SWIFT as WhatsApp for bankers. It's a highly secure communications network that banks can use to coordinate bank-to-bank payments, otherwise known as wire transfers, between each other on behalf of their customers, using specialized financial languages like ISO 20022 or FIN.

The SWIFT network, owned by the Society for Worldwide Interbank Financial Telecommunication, a non-profit based in Belgium, has over the years become the global standard for banks to signal cross-border database updates. There is currently no alternative. Decades ago, everyone gravitated toward using the SWIFT network for international payments; so that's where a banker has gotta be.

Canada's SWIFT exposure is especially problematic. Many of the world's largest nations only rely on the SWIFT network for international payments; they do not use SWIFT for domestic payments. For security reasons, these nations have built their own bespoke messaging networks and require their banks to use the domestic network for making within-country wires. For example, India has the Structured Financial Messaging System (SFMS), the U.S. uses FedLine*, and Japan has the Zengin Data Telecommunication System.

Yet a group of smaller countries, including Canada, also rely on the SWIFT network for domestic payments. The UK, Australia, and South Africa are part of this group, too. (I wrote about this domestic reliance a few years ago, if you want more details.) What it boils down to is that if a Toronto-based customer of Royal Bank wants to wire $1 million to a Calgary-based customer of TD Bank, it is the SWIFT network that conducts the communications necessary to complete this within-Canada wire payment.

That is, our domestic payment system is fully reliant on a piece of Belgian infrastructure. And this domestic reliance is a huge weakness.

Cutting countries off from SWIFT has become one of the U.S.'s standard tools for disciplining enemies. Over the years North Korea, Iran, and Russia have all undergone it. Being de-SWIFTed isn't a killing blow, but it makes it much tougher for the offending nation's banks to interact with counterparties to make payments. Without SWIFT, bankers fall back on ad hoc networks of fax machines, email, and telex. Efficiency is replaced by clunky, error-prone workarounds.

In 2025, Canada suddenly finds itself in the same boat as North Korea, Iran, and Russia: we are all U.S. targets (or is Russia about to become a U.S. friend again?) And so Canada faces a genuine threat of being de-SWIFTed. Some of you are thinking: "But wait, JP. SWIFT is a European-based platform. As a liberal democracy, Europe is on Canada's side. They would never allow us to be cut off, right?"

Yes and no. The U.S. market is far bigger than the Canadian market. Given a U.S. ultimatum between disconnecting Canada's banking system and facing U.S. punishment, SWIFT and the Europeans may very well choose to take the path of least resistance and cut Canada off.

A potential European betrayal is precisely what happened to Iran when it was severed from SWIFT in 2018. Recall that the U.S., Europe and other partners had signed a nuclear deal with Iran in 2015 whereby Iran agreed to cease its efforts to get the bomb in exchange for a cessation of western sanctions. Trump reneged on the deal in 2018, enraging the Europeans, who wanted to continue honoring it. The U.S.'s 45th president began to pressure SWIFT to remove Iran from its network, threatening sanctions and travel bans on SWIFT execs. At the time, I thought SWIFT might resist Trump's pressure. Europe remained supportive of Iran, after all, and the EU's "blocking statute" makes it illegal for EU firms like SWIFT to comply with American sanction demands. But Europe caved and Iran was quietly unplugged from SWIFT.

In short, Canada, like Iran, can't rely on Europe to uphold its SWIFT access.

As I said earlier, a de-SWIFTing is doubly serious for Canada. Not only would it sever our banks from the sole communications network through which they can make foreign payments. We would also lose our ability to make local wire payments in Canadian dollars. Need to pay $500,000 by wire to close a house purchase? Too bad. It won't go through.

For those interested in visuals, the chart below illustrates our SWIFT dependence. Note how all arrows pass through the SWIFT network:

How a Canadian wire transfer works: When a Canadian bank (i.e. the "instructing agent") makes a wire payment to another Canadian bank (the "instructed agent") on behalf of a customer, it starts by initiating a PACS message. This message is sent to the SWIFT network, which notifies Lynx, Canada's high value payments system. All Canadian banks have accounts at the Bank of Canada, our nation's central bank. Lynx's role is to debit the central bank account of the first bank and credit the account of the second bank. A confirmation message then flows back from Lynx to SWIFT and on to the recipient bank. SWIFT is central to this entire flow. All arrow lead to or away from it. If SWIFT is no longer permitted to bridge Canadian banks and Lynx because of a Trump ban, then this entire payments flow ceases to function. Image source: Payments Canada

While we can't do much about losing access to SWIFT's international payments services, we do have options for mitigating the effects of lost access on local transactions. Canada must build its own proprietary domestic financial messaging network — urgently. For argument's sake I'll call it MapleFIN. Once built, the government could require domestic banks like BMO and TD Bank to support MapleFIN along with the existing SWIFT option, giving financial institutions two routes for passing on financial messages to other Canadian banks. Then if we are threatened with a de-SWIFTing, at least our domestic payments system won't be paralyzed; we can fall back on MapleFIN.

The oddest thing for me about the sudden emergence of the U.S. threat is that I've been looking to bad actors like Russia and Iran for inspiration on how Canada must harden itself. Like Canada, Russia was historically dependent on the SWIFT network for "almost all" domestic transactions. For many years it had no domestic financial messaging system. Then Russia unjustly invaded Crimea in 2014. It was only at that point that, realizing its vulnerability, the rogue nation belatedly built its own domestic messaging network: the Sistema peredachi finansovykh soobscheniy, or System for Transfer of Financial Messages (SPFS). When Russia's banks finally began to be de-SWIFTed in 2022, they were cut off from making cross-border payments, but at least they could fall back on SPFS for making domestic payments, saving its economy from all sorts of extra chaos.

Iran, too, has its own domestic financial messaging system, having introduced SEPAM in 2013, so when Trump's 2018 de-SWIFTing hit, at least Iran's domestic payments still went through.

We need to do what Russia and Iran did and build domestic payments networks.

A recent design change by the European Union really drives home the point that no nation should be 100% reliant on SWIFT. Like Canada, the EU has always used SWIFT for all of its domestic financial messaging traffic. SWIFT is based in the EU, so you'd think that Europeans would be comfortable being wholly dependent on it. But they aren't. In 2023, European Central Bank modified the domestic payments system so that in addition to SWIFT, banks could also transmit payment messages via a non-SWIFT competitor, SIAnet. (I wrote two articles, here and here, on Europe's decision to reduce its SWIFT reliance).

I worry that many Canadians are still stuck in the early stages of coping with the loss of our privileged relationship with the U.S. There's plenty of anger and betrayal. Many are in denial and think things will return to normal once Trump's regime comes to an end, assuming it ever does. But if we want to safeguard our economy against the years of instability ahead, we can't just stew. We need to accept that things have changed and quickly move forward to mitigate the threat. Financial messaging systems are not irrelevant bits of financial arcanery. They are a vital part of Canada's plumbing through which a large chunk of the nation's commerce flows. If the plumbing seizes up, our financial lives go on pause. Let's fix this, now.

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*The Federal Reserve used to refer to its network as FedNet, but appears to have switched its nomenclature to FedLine.

If it's crypto it's not money laundering

It appears to be official now. According to the U.S. Department of Justice, when illicit activity is routed via crypto infrastructure, then it no longer qualifies as money laundering.

Earlier this week the Department of Justice's deputy attorney general Todd Blanche sent out an internal staff memo saying that the digital asset industry (read: crypto) is "critical to the nation’s economic development." (Editor's note: it's not.) As such, staff have been instructed to stop targeting crypto platforms such as exchanges, mixers like Tornado Cash and ChipMixer, and offline wallets for the "acts of their end users." 

What does "the acts of their end users" mean? Further clarity arrives deeper into Blanche's memo. It helpfully draws attention to how cartels operating in the fentanyl trade often use digital assets. This is well known. Tether, for instance, is a popular payments platform in the fentanyl trade. (See here, here, and here). And yet, the Department goes on to explain that while it will continue to pursue cartels, terrorist organizations, and other illicit enterprises for their financial crimes, it "will not pursue actions against the platforms that these enterprises utilize to conduct their illegal activities."

This marks a radical departure from long-established financial law on Planet Earth, where financial institutions are generally held responsible for the "acts of their end users," and are pursued when criminals use them to "conduct their illegal activities." It's what's known in law as money laundering.

Money laundering is a two-sided crime. There's the first leg: a criminal who has dirty money. And there is the second leg: the criminal's counterparty, a financial intermediary (a bank, crypto exchange, remittance platform, money courier, or helpful individual) who processes the dirty funds. Both legs are prosecutable. That's precisely what happened to both TD Bank and its cartel-linked customers when they were charged last year. Financial providers are held liable for the crimes of their users.

The same two-sidedness goes for sanctions evasion. There is the sanctioned party and there is the financial platform that facilitates their evasion. Both are indictable.  

If, as Blanche suggests, digital asset platforms are no longer to be targeted for the "acts of their end users," that's effectively saying that the second leg of a money laundering or sanctions violation is no longer a violation, at least not when a crypto platform is involved. So if cartel deposits dirty money at an exchange like Binance which facilitates their crypto transactions, the exchange won't be pursued. Only the cartel will be.

In effect the entire technology has been handed a get-out-of-money-laundering-jail-free card. A detached observer could safely assume that crypto platforms will respond by easing up on their compliance measures—they won't be indicted, after all—which, in turn, will allow more bad actors to make use of their services.

The memo provides more details. It's quite likely that both the ongoing Tornado Cash case (which I've written about extensively) and the ChipMixer case will be dropped, as the memo explicitly states that the Department will no longer target mixing and tumbling services. Tornado Cash, a smart-contract based mixer, operates with a large proportion of its infrastructure running through automated code, whereas first-generation mixers like ChipMixer are entirely human-operated. The latter had mostly disappeared thanks to a series of successful criminal convictions, but will spring back into action as the threat of indictment recedes—leading to more anonymity for the entire system, including for criminals.

The memo's prohibition against Department lawyers targeting "offline wallets" likely refers to "unhosted wallets," which presumably applies to stablecoins—a highly popular type of crypto token pegged to national currencies. Stablecoin users can either hold balances of a stablecoin like Tether or USDC in unhosted format, within their personal crypto wallets, or hold them with the issuer for redemption into actual dollars, in which case they become "hosted." The implication seems to be that if unhosted stablecoins are used by bad actors, the issuers themselves won't be targeted. It's a fantastic policy—if your goal is to encourage fentanyl cartels to use stablecoins.

This decriminalization of crypto money laundering is a ratification of how much of the crypto ecosystem already operates. Just last week, for example, I wrote about stablecoin issuers like Tether and Circle allowing Garantex, a sanctioned Russian exchange, to hold balances of their stablecoins. The issuers seem to believe that providing access to illicit end users like Garantex is legal. And now, it seems, the government has confirmed their view by no longer targeting unhosted wallets for the "acts of their end users."

Now that we've explored some of the immediate legal and technical consequences of this decision, it's worth asking: who on earth benefits from this sudden shift in policy? Because clearly most people will be made worse off. 

I'm only speculating, but here's who this policy may be designed to appease and/or reward:

• Trump-voting libertarians who have arrived at the odd belief that money laundering shouldn't be a crime.
• San Francisco crypto entrepreneurs who want to create financial platforms on the cheap, without the burden of building expensive compliance programs to prevent criminals usage. These entrepreneurs also want their crypto platforms to have access to bank accounts, but banks have been hesitant due to the high risk of crypto-based money laundering. Now that crypto has immunity, banks no longer have to worry. Crypto entrepreneurs voted for Trump, funded him, and are a big part of his administration. This is their payback.
• Trump himself who seems intent on building a murky authoritarian system of bribery and patronage à la Putin or Orban. This system requires money laundering-friendly financial infrastructure, and the Department's memo may be an early step to creating it. (The Trump family, with its many crypto-based entrepreneurial efforts, is also part of the second group.)

In the long term, banks and other traditional providers may benefit, too. With crypto-based finance now unburdened of a major law, every single financial provider operating outside of this crypto-friendly zone, such as traditional banks and fintechs, will be incentivized to switch their database infrastructure over to crypto in order to qualify for this loophole. That means shifting your Wells Fargo U.S. dollar savings account over to a blockchain-based dollar saving account. Doing so will allow banks and fintechs to cut compliance costs and increase their profits.

Once the entire financial sector has migrated through the loophole, it will no longer be a crime to launder funds for criminals. And with mixers no longer being charged by the Department of Justice, that means blanket anonymity for everyone.

As far as the public's welfare goes, the memo is awful. Like theft and fraud, money laundering is immoral and should be punished. Giving one stratum of society a free pass from any law, whether that be money laundering or theft or murder, erodes trust in government and the financial-legal system.

More broadly, society's money laundering laws are a key defence against all types of other crimes. The so-called predicate offences to money laundering such as robbery, human smuggling, and corruption become much more tricky to carry out when, thanks to money laundering laws, the financial system does its best to shut them out. The dissuasive effect engendered by this effort stops many would-be criminals from ever leaving the licit economy. Take away those laws and the case for becoming a criminal becomes much more persuasive.

Why sanctions didn’t stop Russia's Garantex from using stablecoins

Stablecoins, a new type of financial institution, are unique in two ways. First, they use decentralized databases like Ethereum and Tron to run their platforms. Secondly, and more important for the purposes of this article, they grant access to almost anyone, no questions asked. 

I'm going to illustrate this openness by showing how Garantex, a sanctioned Russian exchange that laundered ransomware and darknet payments, has enjoyed almost continual access to financial services offered by stablecoin platforms like Tether and USDC throughout its six year existence, despite a well-known reputation as a bad actor. 

Last month, law enforcement seizures combined with an indictment and arrest of Garantex's operators appear to have finally severed Garantex's stablecoin connection... or not. Evidence shows that Garantex simply rebranded and slipped right back onto stablecoin platforms.  

Stablecoins' no-vetting model is a stark departure from the finance industry's default due diligence model, adhered to by banks (such as Wells Fargo) and fintechs (such as PayPal). We all know the drill—provide two pieces of ID to open a payments account. Requirements for businesses will probably be more onerous. Anyone on a sanctions list will be left at the door. Banks and fintechs must identify who they let on their platforms because the law requires it.

By contrast, to access the Tether or USDC platforms, the two leading U.S. dollar stablecoins, no ID is required. Anyone can start using stablecoin payments services without having to pass through a due diligence process. Sanctioned customers won't get kicked off, as Garantex's long-uninterrupted access shows. Regulators seem to tolerate this arrangement—so far, no stablecoin operators have faced penalties for money laundering or sanctions evasion.

A quick history of the Tether-Garantex nexus

Garantex became notorious early on for its role in laundering ransomware payments. Russian ransomware gangs hacked Western firms, extorted them for bitcoin ransoms, and cashed out at Moscow-based exchanges like Garantex. Garantex also became a popular venue for laundering darknet-related proceeds, particularly Hydra, once the largest darknet market. Reports allege that the exchange's shareholders have Kremlin links and that terror groups Hezbollah and Quds Force have used it.

Founded in 2019, Garantex was connected to Tether's platform by August 2020. We know this because an archived version of Garantex's website from that month show trading and payment services being offered using Tether's token, USDT.

Archived Garantex.org trading page from March 2024 with USDT-to-ruble, Dai-ruble, and USDC-ruble markets [link]

This connection to Tether allowed Garantex's customers to transfer their Tether balances to Garantex's Tether wallet, in the same way that a shopper might use their U.S. dollar account at PayPal to make payments to a business with a PayPal account. This allowed Garantex's users to trade U.S. dollars (in the form of Tether) on its platform for bitcoins or ether, two volatile cryptocurrencies, and vice versa. The Tether linkage also meant that Garantex could offer a market for trading ruble-USD.

By April 2022, Garantex's bad behaviour had caught up to it: the exchange was sanctioned by the U.S. Treasury's Office of Foreign Asset Control (OFAC). U.S. individual and entities were now prohibited from doing business with Garantex. Out of fear of being penalized, most non-Russian financial institutions would have quickly severed ties with it. Yet Tether, based in the British Virgin Islands at the time, permitted its relationship with Garantex to continue without interruption. Archived copies of Garantex's trading page from mid-2022 and 2023 show that Tether-denominated services were still being offered.

The Wall Street Journal reported in 2023 that around 80% of the exchange’s trading involved Tether, despite sanctions being in place. The net amounts were not small. According to Bloomberg, an alleged $20 billion worth of Tether had been transacted via Garantex post-sanctions. A 2024 Wall Street Journal report revealed that sanctions-evading middlemen used Tether to "break up the connection" between buyers like Kalashnikov and sellers in Hong Kong, with Garantex serving as their venue for acquiring Tether balances. 

Finally, analysis from Elliptic, a blockchain analytics firm, alleges that Garantex offered USDT trading services to North Korean hacking group Lazarus in June 2023. This transaction flow is illustrated below:

The Garantex/Tether nexus in 2023: Elliptic alleges that North Korean hackers stole ether from Atomic Wallet, converted it to Tether using a decentralized exchange 1inch, and then sent Tether to Garantex to trade for bitcoin. (Click to enlarge.) Source: Twitter, Elliptic

Tether's excuse for not off-boarding sanctioned entities such as Garantex? A supposed lack of government clarity. 

When Tornado Cash was sanctioned in 2022, for instance, the company said that it would "hold firm" and not comply because the U.S. Treasury had "not indicated" whether stablecoin issuers were required to ban sanctioned entities from using what Tether refers to as "secondary market addresses." Translating, Tether was saying that if bad actors wanted to use Tether's platform to transact with other Tether users (i.e. in the "secondary market"), it would let them do so. Tether's only obligation, the company believed, was to stop sanctioned users from asking Tether itself to directly cash them out of the platform into U.S. dollars (i.e. the "primary market").

This is quite the statement. Imagine if PayPal allowed everyone—including sanctioned actors—to open an account without ID and send funds freely within its system, only intervening when bad actors asked PayPal to cash them out into regular dollars. That was Tether's stance. Or if Wells Fargo let sanctioned actors make payments with other Wells Fargo customers, but only stopped them from withdrawing at ATM. Banks and fintechs can't get away with such a bare bones compliance strategy; they must do due diligence on all their users. But Tether seemed to believe that a different set of rules applied to it.

In December 2023, Tether reversed course. It would now initiate a new "voluntary" policy of freezing out all OFAC-listed actors using its platform, not just "primary market" sanctioned users seeking direct cash-outs. This brought Tether into what it described as "alignment" with the U.S. Treasury. Soon after, Tether froze three wallets linked by OFAC in 2022 to Garantex.

However, this action was largely symbolic. By the time Tether froze those wallets, Garantex had already abandoned them and opened new ones, thus allowing the exchange to maintain access to Tether's platform. Tether's no-vetting model permitted this pivot. Archived versions of Garantex's trading page show that it continued offering Tether services throughout 2024 and early 2025.

The U.S. Department of Justice recently confirmed Garantex's tactic of replacing wallets in its March 2025 indictment of the exchange's operators. It alleges that Garantex frequently cycled through new Tether wallet addresses—sometimes on a daily basis—to evade detection by U.S.-based crypto exchanges like Coinbase and Kraken, which are legally required to block customer payments made to sanctioned entities.

That the relationship between Tether and Garantex continued even after Tether's supposed 180 degree turn to "align" itself with the U.S. government is backed up by several reports from blockchain analytics firm Chainalysis. The first, published in August 2024, found that a large purchaser of Russian drones used Garantex to process more than $100 million in Tether transactions. The second describes how Russian disinformation campaigners received $200,000 worth of Tether balances in 2023 and 2024, much of it directly from Garantex. In a March 2024 podcast, Chainalysis executives allege that "a majority" of activity on Garantex continued to be in stablecoins.

After years of regular access to Tether's stablecoin platform, a rupture finally occurred earlier this month when Tether froze $23 million worth of Garantex's USDT balances at the request of law enforcement authorities. The move came in conjunction with a seizure by law enforcement of Garantex's website and servers. 

Garantex's website was seized in March 2025 by a collection of law enforcement agencies.

In a press release, Tether claimed that its actions against Garantex illustrated its ability to "track transactions and freeze USDt." But if Tether was so good at tracking its users, why did it connect a sanctioned party like Garantex in the first place, and continue to service it for over four years? Something doesn't add up.

Not just Tether: other stablecoins offered Garantex access, too

Tether doesn't appear to have been the only stablecoin platform to provide Garantex with access to its platform. MakerDAO (recently rebranded as Sky) and Circle Internet may have done so, too.

Circle, based in Boston, manages the second-largest stablecoin, USDC. When OFAC put Garantex on its sanctions list in April 2022, Circle was quick to freeze one of the designated addresses. It did no hold any USDC balances. However, like Tether, Circle's no-vetting policy means that it doesn't do due diligence on users (sanctioned or not) who open new wallets, hold USDC in those wallets, and use them to make payments within the USDC system. Circle only checks the ID of users who ask it to cash them out. Thus, it would have been a cinch for Garantex to dodge Circle's initial freeze: just open up a new access point to the USDC platform. Which is exactly what appears to have happened.

On March 30, 2022, Garantex used its Twitter/X account to announce that it was offering USDC-denominated services. Beginning at some point in the first half of 2022, close to the time that the U.S. Treasury's sanctions were announced, Garantex began to list USDC on its trading page (see screenshot at top). The exchange's trading page continued to advertise USDC-denominated financial services through 2023, 2024, and 2025 until its website was seized last month. 

Tether, Circle's competitor, proceeded to freeze $23 million worth of USDT on behalf of law enforcement authorities, as already outlined. However, respected blockchain sleuth ZachXBT says that Circle did not itself interdict Garantex's access to the USDC payments platform, alleging that "a few Garantex addresses" holding USDC had not been blacklisted.

MakerDAO is a geography-free financial institution that maintains and governs the Dai stablecoin, pegged to the U.S. dollar. Archived screenshots show that Garantex added Dai to its trading list by September 2020, not long after the exchange had enabled Tether connectivity. According to blockchain analytics firm Elliptic, Russian ransomware group Conti has used Garantex to get Dai-denominated financial services. Garantex is able to access the Dai platform because MakerDAO uses the same no-vetting model as Tether. In fact, MakerDAO takes an even more hands-off approach than the other stablecoin platforms: it didn't seize any of the original 2022 addresses emphasized by OFAC. That's because Dai was designed without freezing functionality.

Not vetting users is lucrative

Providing financial services to a sanctioned Garantex would have been profitable for Tether and competing stablecoin platforms managed by Circle and MakerDAO. 

All stablecoins hold assets—typically treasury bills and other short term assets—to "back" the U.S. dollar tokens they have issued. They get to keep all the interest these assets generate for themselves rather than paying it to customers like Garantex. If we assume an average interest rate of 5% and that Garantex maintained a consistent $23 million in Tether balances over the 34 months from April 2022 (when it was sanctioned) to March 2025 (when it was finally frozen out), Tether could have earned approximately $3.2 million in interest courtesy of its relationship. 

Not only does their no-vetting model mean that stablecoin platforms get to earn ongoing income from bad actors like Garantex, this model also seems... not illegal? Stablecoin legal teams have signed off on the setup, both those in the U.S. and overseas. Government licensing bodies like the New York Department of Financial Services don't seem to care that licensed stablecoins don't ask for ID, or at least they turn a blind eye. (Perhaps these government agencies are simply unaware?) Nor has the U.S. Department of Justice indicted a single stablecoin platform for money laundering, sanctions violations, or failing to have a compliance program, despite it being eleven years now since Tether's no-vetting model first appeared. The model seem to have legal chops. Or not?

Banks and fintechs are no doubt looking on jealously at the no-vetting model. Had either PayPal or Wells Fargo allowed Garantex to get access to their payments services, the punishment would have been a large fine or even criminal charges. Sanctions violations are a strict liability offence, meaning that U.S. financial institutions can be held liable even if they only accidentally engage in sanctioned transactions. But more than a decade without punishment suggests stablecoins may be exempt.

This hands-off approach benefits stablecoins not only on the revenue side (i.e they can earn ongoing revenues from sanctioned actors). It also reduces their costs: they can hire far fewer sanctions and anti-money laundering compliance staff than an equivalent bank or fintech platform. Tether earned $13 billion in last year with just 100 or so employees. That's more profits than Citigroup, the U.S.'s fourth largest bank with 229,000 employees, a gap due in no small part to Tether's no-vetting access model. 

The coming financial migration?

Zooming out from Garantex's stablecoin experience, what is the bigger picture? 

I suspect that a great financial migration is likely upon us. Financial institutions can now seemingly provide services to the Garantex's of the world as long as the deliver them on a new type of substrate: decentralized databases. If so, banks and fintechs will very quickly shift their existing services over from centralized databases to decentralized ones in order to take advantage of their superior revenue opportunities and drastically lower compliance costs. 

This impending shift isn't from an inferior technology to a superior one, but from an older rule-bound technology to a rule-free one. PayPal recently launching its own stablecoin is evidence that this migration is afoot.

The argument many stablecoins advocates make to justify the replacement of full due diligence with a no-vetting access model is one based on financial inclusion. Consumers and legal businesses in places such as Turkey or Latin America, which suffer from high inflation, may want to hold digital dollars but don't necessarily have access to U.S. dollar accounts provided by local banks, perhaps because they don't qualify or lack trust in the domestic banking system. An open access model without vetting solves their problem.      

What about the American voting public? Do they agree with this migration? The last few decades have been characterized by a policy whereby the government requires financial institutions to screen out dangerous actors like Garantex in order to protect the public. Forced to the fringes of the financial system, criminals encounter extra operating dangers and costs. The effort to sneak back in serves as an additional choke point to catch them. To boot, the additional complexity created by bank due diligence serves to dissuade many would-be criminals from engaging in crime. Is the public ready to let the Garantexes back in by default? I'm not so sure it is.

Tether is available at Grinex, a Garantex reboot. [link]

Garantex's stablecoin story didn't end with last month's seizures and indictment. According to blockchain analytics firm Global Ledger, the exchange has been renamed Grinex and continues to operate. Tether services are already available on this new look-alike exchange, as the screenshot above reveals. Global Ledger says that $29.6 million worth of Tether have already been moved to Grinex as of March 14, 2025. 

This is the reality of an open-access, no-vetting financial system: bad actors slip in, eventually get cut off, and re-enter minutes later—an endless game of whack-a-mole that seems, for now at least, to be tolerated. It will only get larger as more financial institutions, eager to cut costs, gravitate to it.

Canadian guilt, Russian oil

We Canadians are overwhelmingly pro-Ukraine and anti-Putin, so when the CBC published an expose last week about "banned Russian oil" sneaking into Canada, it was read in despair by most of us. What an awful failure of Canadian sanctions policy. 

As with a lot of sanctions media coverage, I saw things a bit differently: "Not bad. We're doing our part!" That's because if you add some more context to the CBC article, the data that it presents can be read as good news.

The article takes issue with 2.5 million barrels of refined oil products made from Russian-produced crude that have been indirectly imported into Canada since the start of Putin's invasion of Ukraine in 2022. Given that around 1,000 days have passed since the invasion, that works out to roughly 2,500 barrels per day of Russian-linked refined oil products arriving on Canadian shores. (Analyzing oil flows on a per-day basis is industry standard and also makes it easier for our brains.)

In the grand scheme of things, 2,500 barrels per day is a drop in the bucket. Canada consumes around 1.6 million barrels of refined oil products per day, according to CAPP, which includes stuff like gasoline, diesel, and jet fuel. So just 0.1% of our consumption is Russia-tainted. Even so, every barrel matters, and we should strive to avoid any contribution to Putin's war chest.

But there's more context. 2,500 barrels per day of Russian refined oil products is far less than what we imported prior to the war. According to the Canada Energy Regulator (CER), between 2017 and 2022 Canada was regularly importing around 10,000 barrels per day of refined petroleum products directly from Russia (see chart below). After banning imports of Russian crude and refined oil products, Canada's direct imports fell to zero in 2023. Into this void, indirect imports of 2,500 barrels per day of Russian-linked refined products, the flows that the CBC spotlights, have emerged.

A 75% decline from 10,000 barrels per day to 2,500 barrels per day is not too shabby.

Canada's direct imports of Russian refined petroleum products, which hit zero in 2023. Source: CER

2,500 barrels is still not zero. But we can also take comfort from the fact that those barrels are not as profitable for Russia as they used to be. In the pre-war era, Canada was importing refined petroleum products directly from Russia, but in the post-war era we are importing Russian oil indirectly via a third-party, India. More specifically,  oil in its raw form -- crude oil -- is being shipped all the way from Russia to India by tanker, where it is upgraded by Indian refineries, and only then is it onshipped to Canada.

This new workflow is a big downgrade for Russia. Before it can be used, crude oil has to be converted into pricier consumable types of fuel like gasoline for cars and jet fuel for planes. Upgrading crude oil creates extra profits for whoever does it. Russia's refineries used to capture the entire upgrading margin. They refined the raw oil after it was pulled out of the ground and then regularly sent 10,000 barrels per day of the final product to Canada. But now India is capturing those extra profits on the 2,500 barrels per day that are sent to Canada.

So not only has the quantity of Russian-linked refined products imported by Canada shrunk by 75% since the war began, but thanks to the interposition of Indian refiners at the expense of Russian ones, the quality of Russia's revenue stream has been downgraded: pound-for-pound, Russia's indirect exports to Canada are a far less lucrative for Putin than they were back in 2021, because his refining margin has disappeared.

Compounding Russia's woes is the much more circuitous route that its oil must now take. Prior to 2022, Russian refined oil exports were loaded onto boats in Russian ports like Saint Petersburg and shipped via the Baltic Sea to Canada, around 4,000 nautical miles away. That's a 15-day voyage according to Sea-Distances.

These days, that 15-day voyage has tripled, even quadrupled. First, Russian crude oil must travel from the Baltic to India, a 7,500 nautical mile journey that can take 30 days. That's if it goes through the Suez canal. Passing around the southern tip of Africa amounts to a 12,000 mile trip taking up to 50 days. Once refined in India, the product must travel another 8,000 miles from India to eastern Canada. 

What an incredible amount of travel to get a barrel of Russian refined oil to Canadian markets! A good way to visualize these new transportation frictions is provided by the Kyiv School of Economics, which charts the volume of Russian oil being transported by oil tankers over time. Thanks to the forced rerouting of crude to less efficient routes as countries like Germany and Canada close their borders to Putin, Russia's oil on water is 163% higher than the pre-invasion average.

Record volumes of Russian oil on water is not a good thing for Putin. It mean higher transportation costs. Source: KSE

The extra transportation and insurance costs that "oil on water" entails inevitably eat into the final price that Russia can negotiate with buyers like India for its barrels of crude. For these long distances to be financially worthwhile for Indian businesses, they will only buy Russian crude at a discount to the going world price. According to the Dallas Fed, the Russia discount regularly clocks in at around $20 below the market price. This constitutes a big step down for Russia -- prior to the war it was receiving the full world price.

The upshot is that Canadian imports of Russian oil are down, and even though some Russian refined petroleum products are indirectly making their way to Canada, this is only after we've extracted our pound of flesh from Putin by forcing him to give up his refining margin and by obliging him to accept a crude oil price discount on account of distance traveled. So let's take some pride from that.

Does that mean we shouldn't do anything about our indirect imports of Russian oil product?

I want to clarify that Canada isn't importing "banned" products or breaking Russian sanctions. For better or for worse, the coalition's sanction on Russian crude oil have been designed to allow crude to continue to flow around the world, the intent being to avoid a big spike in oil prices while still hurting Russia. The 2,500 barrels of indirectly-refined refined oil we get each day are fair game.   

But that doesn't mean Canadians should do nothing. The CBC article is a good effort to name-and-shame certain Canadian importers that are accepting Russian-linked crude from third-parties, including Everwind Fuel's Point Tupper oil storage facility in Nova Scotia. C'mon, Everwind. Why not choose better trading partners, ones who aren't acting as go-betweens for Putin?

However, the best step we can do to counter Russia is to focus on producing more renewables, crude oil, and other commodities, as well as to find reliable ways to get these resources to market. 

Unlike Europe and the U.S., which have plenty of economic and financial heft, Canada doesn't have any sizable economic chokepoints that we can lever to hurt Russia. We could cut down on the 2,500 barrels per day of Russian-linked oil imports, but as laudable as that might be it doesn't constitute a genuine chokepoint. Canada's edge is that our economy is remarkably similar to Russia. Both of us extract a bunch of resources. The more we compete with Putin in resource extraction, the more we reduce the prices he relies on, thus impairing his ability to fund his invasion of Ukraine.

Tornado Cash un-OFAC'ed

The next chapter in the Tornado Cash saga just dropped. Last week a court ruled last that Tornado Cash, a bot that can be used for obfuscating crypto, is safe from being sanctioned.

I first wrote about Tornado Cash in 2021, before its legal troubles began, warning of the risks ahead. I've been tracking Tornado's legal saga since then. (See here | here | here ). The saga serves as a bellwether for how financial services hosted on blockchains are to be sliced and diced under existing laws, in particular the crucial anti-money laundering statutes and sanctions laws. More generally it foreshadows how autonomous techno-beings, many of which don't yet exist, are to be treated by the law.

In the newest chapter of the saga, a court ruled that America's sanctions authority, the U.S. Treasury's Office of Foreign Assets Control (OFAC), does not have the authority to sanction a certain type of smart contract, or string of autonomous code, that undergirds Tornado Cash: its so-called immutable contracts.

Recall that in August 2022, OFAC sanctioned Tornado Cash, which accepts traceable crypto from users and returns it in untraceable format. Tornado had been used by the sanctioned North Korean hacker group Lazarus to obfuscate its financial tracks. OFAC listed Tornado Cash's website tornado.cash along with 53 Ethereum addresses.

The sanctions were relatively effective. Americans could no longer use the bot without risking fines or imprisonment. Those who had funds deposited in Tornado had to ask OFAC for special permission to withdraw them. In the months after the sanctions were announced, usage of the privacy bot plunged and the amount of crypto deposited fell by over half.
 
After two different sets of plaintiffs challenged OFAC's actions in court, the appeals court in one of the cases returned a verdict last week. An immutable smart contract is "unownable, uncontrollable, and unchangeable—even by its creators," and therefore it doesn't qualify as property. Because OFAC's sanctioning power is limited to that which is property, it follows that OFAC cannot sanction immutable smart contracts.

This not-property ruling only applies to twenty immutable Tornado Cash contracts that were on OFAC's sanctions list. Tornado's mutable contracts, those that can be controlled and changed, remain property—and thus can stay on the list of sanctioned contracts. Unless OFAC wins on appeal, it will presumably have to unsanction those twenty immutable contracts.

Now, it's possible that as long as the remaining sanctioned mutable contracts are crucial to the functioning of the Tornado Cash bot, the revised sanctions blacklist will still have an effect. And if OFAC adds other key mutable Tornado Cash smart contracts to its list (say like the contracts allowing governance, which for some reason were not originally sanctioned), American users will continue to steer clear of Tornado Cash, the bot's anonymizing capacities remaining lower than otherwise, thus diminishing its ability to serve North Korean interests. 

But if not, what can OFAC do? 

Sanction users, not code

I've already done a bit of digging on this question. In response to the sanctions, I wrote an article in late 2022 entitled: How to stop illegal activity on Tornado Cash (without using sanctions) The gist was to explore alternative tools for countering illicit activity on Tornado rather than the blunt tool of sanctioning its actual smart contracts. What I suggested was to apply pressure to the users of the smart contracts. "Rather than punishing code, penalize the people who use the code."

The logic goes like this. Any user who deposits crypto to Tornado Cash, even someone with clean crypto, is providing North Korea with prohibited financial services, the Tornado bot being the means by which the two sides are connecting as counterparties. Whether intentional or not, a user's deposits broaden the anonymity set of Tornado Cash, or its ability to obfuscate larger amounts of illicit funds sourced from sanctioned counterparties like Lazarus.

Think of it as sanctioned North Korean users passing on sanctions taint to all other Tornado Cash users by virtue of everyone interacting via the same bot, Tornado Cash. This taint spreads to those who deposited their crypto (clean or dirty) to Tornado at the same time as Lazarus and/or those who have continued to deposit to it in light of the known fact that the North Korean group regularly deposits stolen funds to the platform.

OFAC issues a public alert stating that any foreigner can and will be sanctioned if their funds interact with North Korean funds on Tornado Cash. In response, some foreign users will risk being designated and continue to engage with Tornado. Many will not. As for U.S. users, OFAC can threaten them with potential civil monetary penalties if they aid North Korea using Tornado as their a tool. A $10,000 fine for interacting with sanctioned North Korean actors via the Tornado Cash bot will probably discourage most usage.

Another core set of Tornado Cash users who OFAC has legal leverage over are the relayers—real life individuals who provide an extra layer of privacy to Tornado Cash users. (I explain here why relayers are necessary for full privacy). OFAC can threaten foreign relayers with sanctions and U.S.-based relayers with civil monetary penalties.

Pressuring these various groups of users won't stop Tornado Cash code from functioning, but it will certainly constrain the activity it facilitates, and thus make it harder for North Korea to anonymize its funds. And it is consistent with the court's not-property ruling because users, not contracts, are being targeted.

I'm not saying that OFAC will follow this playbook, or that it should, but it certainly is an option. There is another route, though, and that is to go to Congress and ask for the ability to put sanctions on immutable entities. 

More broadly, Tornado Cash may just be the first in an emerging population of unownable and uncontrollable techno-beings—bots, machines, drones, androids, AI agents,  automatons, and golems—that operate independently of human control, many of which will end up doing very dangerous things. Society may want the legal ability to protect its members from these immutable contraptions, including by sanctioning them.

For instance, imagine the following scenario...

A Russian AI-guided assassin bot

If a Russian assassin is regularly poisoning people (including U.S. citizens) for criticizing Putin, OFAC can sanction that assassin, thus preventing any American entity from dealing with him and blocking all of his accounts, his car, and his interests in various companies. That might not stop the assassin, but it'll make his job more difficult. In doing so, OFAC is simply fulfilling its mandate to use its sanctioning powers to protect Americans.

Say the assassin creates an artificial intelligence and imbues it with all of his assassin's lore, providing it with an artificial body and then throwing away the keys, rendering the robot immutable. The court's recent not-property ruling suggests that while OFAC can ably defend Americans from the flesh and blood assassin, it cannot protect them from the assassin's immutable killing robot—even though the robot performs the precise same killing function as the living assassin using the exact same techniques.

This is obviously an incongruity, one that seems like it should be fixed. Or is there a specific reason why we should provide legal safe harbor to all unownable and uncontrollable techno-beings? Feel free to explain in the comments.

In any case, OFAC's efforts to apply its national security mandate to Tornado Cash are probably not over. Let's see how it responds. Some sort of resolution is important because we are still in the early stages of being inundated with self-guided autonomous agents.

A glass half-full take on Caucasus sanctions evasion

Ed Conway of Sky News recently published a very good investigation on sanctions evasion being carried out through the Caucasus. He visits the Lars border crossing between Georgia and Russia to document how smugglers are openly moving British and German luxury cars into Russia, in contravention of sanctions on Russian luxury car imports.

In a subsequent interview, Conway describes this as the the "most depressing" bit of journalism he has ever worked on. He agrees with his host that the west's sanctions are "performative," in that they are simply there to make Western voters feel good, but in reality achieve very little. He concludes: "The toughest sanctions regime in history, is anything but..."

For anyone who supports Ukraine's cause, this is all difficult to watch. However, I think that Conway has arrived at a glass half-empty interpretation of the details of his own reporting. What follows is my glass-half-full take on Conway's visit to the Caucasus. What I'm hoping to convey – using the details from his video – is that we (i.e. the West) are doing ok. Yep, we could be doing better (and hopefully will), but let's take heart at what we've achieved to date.

Conway tracks two new Range Rovers being smuggled from Tbilisi, Georgia's capital, northwards to the Lars border crossing with Russia. Prior to Conway making contact with them, the Range Rovers have already been on a circuitous trek. Manufactured in Solihull, UK in 2024, we learn that the vehicles were originally shipped by Jaguar Land Rover to a dealer in a country that does not share a border with Russia, so not Georgia, but perhaps Turkey or the Emirates. Thus the first leg of their journey would have involved a long trip in a container ship or RORO cargo ship from England to Dubai or Istanbul.

In the second leg, the smugglers who acquired the car in Turkey or UAE paid for it to be shipped to Georgia, either by boat or overland.

In the third leg, which is the only leg that Conway observes, two single trucks can be seen transporting each Range Rover through Georgia to the Lars border crossing along a skinny winding road. The Range Rovers are deposited in a parking lot next to a "forlorn" cafe on the Georgia side of the border (the parking lot appears to have no security), and after a few days a new driver is paid to take the car to the Russia side and leave it there. 

The parking lot where sanctioned luxury cars are stored at the Georgia-Russia border

Now the fourth leg begins. Another driver is contracted to bring the vehicle to its final destination in Russia. This last leg is no small trip, with the biggest Russian markets, Moscow and Saint Petersburg, at a distance of 1,800 km and 2,500 km respectively from the border.  

These successive legs add up to an arduous trip. The shipping bill is likely quite large. To boot, along each leg of this journey additional paper work must be completed, insurance purchased, border officials bribed, storage fees paid, transit license plates acquired, and taxes levied. It is Western sanctions that have imposed this haphazard shipping burden and jungle of administration on Russia's trade in Range Rovers.

But compared to what? Understanding the burden we've imposed on Russia requires that we compare the current state of affairs to the one that was taken away; namely, the highly-developed patterns of trade that existed before sanctions were deployed in 2022. As economists like to say, it's the opportunity cost, or the value of the next-best alternative, that represents the true burden of the sanctions on Russia.

What Russia has lost is the full expertise and capital of Western logistics being brought to bear on the problem of bringing Range Rovers as cheaply and rapidly as possible from Jaguar Land Rover manufacturing plants to Russian buyers. This involved Range Rovers being loaded en masse into highly-efficient RORO cargo ships in the UK and sent – not along a circuitous route passing through the Suez Canal or around the Cape of Good Hope – but by the shortest passage possible, the Baltic Sea.

In the pre-sanctions era, vehicles destined for Russian buyers were unloaded at the Port of Saint Petersburg, Russia's second-largest city, or next door at the massive Port of Ust-Luga. So the goods passed through customs just once, rather than multiple times. These two Baltic ports are purpose-built for handling large amounts of vehicles as efficiently as possible. From there the Range Rovers were transferred to their final Russian destination – not piece-meal, as appears to be the case with the Lars crossing – but in batches via dedicated rail infrastructure and multi-level car haulers. 

Illicit Range Rovers being transported one-by-one via flat bed truck to the Georgia-Russia border

Thanks to sanctions, Russia's first-choice trade route – optimized over many years of trial and error – no longer exists. It's been replaced by an improvised Rube Goldberg trade route involving two much longer sea journeys followed by a crappy single-lane road wending its way through the mountains of Georgia to a border crossing that was never designed to handle large volumes of trade. Once across the border, the contraband cars must be on-shipped using rail or road infrastructure that pales in comparison to the significant economies of scale that characterize the Saint Petersburg/Moscow hub. This is plainly an awful fix.

There's another new cost that needs to be factored in, too: the risk of being caught. Given that it is likely that the dealer in the Emirates or Turkey is part of the sanctions evasion conspiracy, they run the risk of having their dealership status being revoked should Jaguar Land Rover catch them. The dealer will therefore only sell to Russians or other Russian-linked third-parties if the price offered is a high one, enough to compensate them for the risk of losing their franchise.

This extra risk premium, combined with all the additional transportation and intermediation costs listed above, gets embedded into the final all-in price that folks in Moscow will have to pay for a new Range Rover. How high is this price? Certainly much higher than before sanctions were applied. Stephanie Baker, author of Punishing Putin, found in her reporting that western cars in Moscow showrooms were being sold for twice as much as in the U.S. The Times describes luxury Bentleys selling in Moscow for about £400,000 plus £50,000 in VAT—the same model costs just £250,000 in the UK.

Think of this extra price wedge as a sanctions tax on rich Russian car buyers. So yes, cars are squeaking through the West's sanctions blockade, as Conway's reporting reveals, but let's not forget that this comes at a big cost.

A 2,000 km drive from Tbilisi to Moscow

The sanctions tax includes another component. A car is not just a one-time purchase. It represents a commitment to make long chain of repairs and tune-ups over its lifetime. Since the new Range Rovers in Conway's video are illicit, they won't qualify for any dealership support. The warranty is probably void, too. Telematic upgrades provided by Jaguar Land Rover servers in the UK have likely been turned off. Furthermore, since Jaguar Land Rover no longer sends parts to the Russian market, all replacement parts will have to be smuggled over the border, the cost of ongoing car servicing ballooning.

So in the end, voters in the West can take at least some pride from what western sanctions have achieved. By sanctioning luxury cars, we've forced Russian elites to divert more of their finite wealth to paying for circuitous, awkward, and risky pathways into Russia. This means these elites have less left over for other things.

Now, that doesn't mean western voters can relax, and Conway's reporting is good fodder for galvanizing voters to ask their representatives for further action. While sanctions have made the pathway for Range Rovers and other goods into Russia a long and winding one, we need to keep making it even longer and more awkward.

For instance, Conway's video teaches us that there is just one way road connecting Russia to Georgia. What a fantastic chokepoint for western sanctions to target! By working more closely with Georgian authorities, the U.S. and its allies may be able to induce them to add a number of frictions to the Lars border crossing, thus forcing car smugglers to divert contraband vehicles to even more roundabout trade routes, the end result being Russian elites paying an ever higher price.

China is slowly joining the economic war against Russia

I recently shared a chart on Twitter showing Chinese exports of ball bearings to Russia. Here it is:

Having accelerated after Putin's invasion of Ukraine to a run-rate of around US$5-7 million per month in 2023, Chinese ball bearing exports to Russia have been ratcheted down to the $2-3 million level in 2024, about where they stood prior to the invasion.

What's going on here? As Russia's closest ally, shouldn't China be sending Putin all the ball bearings he  wants? Russian tanks are being destroyed every day and ball bearings are a crucial component for building replacements.

Before answering this question, we need a bit of background.

We can think of the economic response to Russia's illegal invasion of Ukraine as progressing in two stages. The first stage of the economic war involved a coalition of liberal democracies (U.S., the EU, Canada, Japan, Switzerland, South Korea, Norway, the UK, and more) reducing their own economic linkages to Russia. Europe drastically scaled down its imports of Russian natural gas. Imports of Russian crude oil into Japan and Germany were slashed to bare bone levels. Western corporations like Coke and John Deere decamped. And the U.S. made an effort to cut down on exports of military goods and so-called dual-use items, which have both commercial and military applications. Ball bearings fall into this category, since they are useful not only for civilian vehicles but also artillery and tanks.

The second stage of the economic war has only recently ramped up, and involves the coalition exerting its influence on non-coalition countries like Turkey, United Arab Emirates, China and India in order to get them to cut down on their economic linkages with Russia.

A key component of this next stage are the U.S. secondary sanctions that were introduced in December 2023 by the U.S. Treasury's Office of Foreign Assets Control ("OFAC"). I've written about them here, here and here. 

In short, if OFAC catches a foreign bank in Shanghai, Delhi, or Dubai facilitating transactions involving Russia's military-industrial complex, including dual-use goods, then that bank risks being cut off from the U.S. banking system. Because the U.S. banking system is so vital, foreign banks prefer to cease all offending Russian trade. This effectively stops Turkish or Chinese ball bearing manufacturers (as well as any other businesses that deals in dual-use goods) from dealing with Russian buyers, since these manufacturers are reliant on their local banks for cross-border payments.

Along with OFAC's introduction of secondary sanctions, there has also been a big step-up in U.S. export controls, which are overseen by a different agency, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS"). The BIS maintains a list of U.S.-produced dual-use items. American and foreign entities are required to get a license from the BIS before exporting, reexporting, or importing certain items on its list.

In March 2024, the BIS broadened the criteria that triggers a licensing requirement. The criteria now includes any involvement of entities listed under fourteen different OFAC sanctions programs, the majority of which are linked to Russia and Ukraine. So for example, if a Hong Kong-based wholesaler intends to re-export a BIS-listed item to a country like Armenia, or transfer that item within Hong Kong, and they fail to realize that the recipient is an actor on one of OFAC's Russia-related sanctions list, then that Hong Kong wholesaler has now violated U.S. export controls. To prevent violations, intermediaries like our Hong Kong wholesale must sharpen their screening requirements.

These new rules, which have been described as a BIS "force multiplier" of OFAC's sanctions program, are intended to assert influence over a broad cross-section of dealers that specialize in indirectly re-exporting goods to Russia. These indirect routes often proceed through a labyrinth of pit-stops in jurisdictions like UAE, Hong Kong, and Kyrgyzstan.

Back to ball bearings. How is the second stage of the economic war progressing? The chart at the top of the page suggests the new measures may be working. Recall too that in February I wrote a post tracking what seemed to be some initial anecdotal indications of success. In the rest of this article I want to use another four or five months of data to provide a more complete picture of how China's interactions with Russia have being affected.

China is crucial to Russia because it has a become a key source of goods destined for the battlefield. According to a report from the KSE Institute, some 44% all Russian parts destined for the Ukraine battlefield were linked to producers in coalition nations, primarily the U.S. These include parts that have been branded by American stalwarts like Intel and Analog Devices. Mainland Chinese producers accounted for 47% of battlefield goods (see chart below). However, progressing further down the value chain to country of dispatch, around 56% of all battlefield parts—including the U.S.-produced ones—get to Russia by way of China, and another 22% via Hong Kong, a special administrative region of China. Together, almost 80% of Russia's battlefield parts are dispatched from these two Chinese sources.

Source: KSE Institute

In other words, not only is China producing its own battlefield goods destined for Russia, but it is also responsible for the final re-routing to Russia of most U.S. produced battlefield goods, at least in the period starting in January 2023 and ending that October.

The items that make up the battlefield goods cited by the KSE Institute are derived from the coalition's Common High Priority List, which includes 50 dual-use items that Russia seeks to procure for its weapons programs, one of which is ball bearings. For the rest of this article I will focus my analysis on the four most important goods on the Common High Priority list: Tier 1 items. Tier 1 items consist of microelectronic circuits (processors, memories, amplifiers, and other circuits) that the BIS says play a "critical role" in the production of advanced Russian precision-guided weapons systems. Russia lacks the ability to produce these items and is reliant on a limited number of global manufacturers, according to the BIS, which only amplifies their importance to Russia.

The chart below shows Chinese exports of Tier 1 items to Russia as reported by China's customs authority. Prior to Russia's invasion of Ukraine, these exports typically came in at around $5 million per month. Post-invasion, they rose to a range of $10 million to $34 million per month, suggesting significant military diversion. 

With the arrival of secondary sanctions in December, monthly Tier 1 exports have fallen below the pre-invasion watermark of $5 million.

The above customs data does not include Hong Kong, which along with mainland China has become a major Chinese source of Tier 1 exports to Russia. To provide a more complete picture, the chart below adds Hong Kong customs data to the mainland customs data. Running between $25-$60 million during most of the war, Tier 1 exports to Russia from the Chinese mainland and Hong Kong have collapsed to sub-$15 million levels this summer, lower than at any point in 2021.

That's quite a big plunge, and certainly suggests that the coalition measures are working with respect to China. Skeptical readers may suggest that China has stopped exporting Tier 1 items directly to Russia only to re-route them via third party nations. According to this theory, the $40-$50 million decline in monthly Chinese exports is being made up by a $40-50 million rise in Chinese exports to, say, Kazakhstan, which eventually make their way to Russia.

Below, I've plotted all Tier 1 exports from the Chinese mainland and Hong Kong to a group of Russian neighbours that includes Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan.

China's Tier 1 exports to Russia's neighbours rose after the invasion, suggesting significant diversion of exports to Russia, and in March 2024 hit $7 million, their second-highest level over the entire 2021-2024 period. However, over the last three months Tier 1 exports to Russia's neighbours have plunged below even pre-invasion levels.

So no, the theory that third-parties have replaced direct China-Russia trade is not borne out in  the data.

In sum, a variety of U.S. economic tools including secondary sanctions, bolstered export controls, and other types of moral suasion seem to be prying China out of the arms of Russia and into the coalition's effort to economically strangle the Russian war machine.

But there's more to be done. China's exports of high priority goods like circuits and ball bearings have fallen in 2024, but they haven't yet hit zero. That will require more pressure on the Chinese government as well as enforcement against Chinese and Hong Kong companies that violate sanctions and/or exchange controls, as well as against intermediaries in third-party nations like Kazakhstan. To further tighten the screws, the coalition will need to constantly broaden the range of economic activity between China and Russia that it deems off-limits. For now, the coalition says that it is perfectly fine for Chinese companies to export cars and vacuum cleaners to Russia, but there may be a time at which that permissiveness will have to change.

In fact, one of the coalition's biggest escalations in the sanctions war occurred in June, with the U.S. secondary sanctions program being extended to include Russian banks. (I wrote about this here.) In effect, Russian financial institutions are now off-limits for Chinese banks (and banks elsewhere, too), unless these Chinese banks want to lose their access to the U.S. banking system. This blacklisting of Russian banks will make it very difficult for Chinese exporters to continue doing business with their now-unbanked Russian counterparts, further eating into the trade relationship between the two nations.

The trade data in the above charts does not yet include the effects of the extension of sanctions to Russia's banks, but I suspect the effects will be significant.

Welcome to the economic war against Russia, China. We hope you continue to do your part.