{"investigation":{"slug":"bitpapa-exchange","entity_name":"Bitpapa Exchange","trust_score":0,"severity_base":null,"score_modifier":-10,"confidence":0.85,"status":"published","content_type":"investigation","summary":"Bitpapa (legally Bitpapa IC FZC LLC, also known as Bitpapa Pay, Baba House LLC and Papa Holding Ltd) is a UAE-registered peer-to-peer cryptocurrency exchange serving mainly Russian, Ukrainian, Belarusian, Kazakh and other CIS users through rouble-to-crypto trading. It has been designated under sanctions programs in four jurisdictions: the United States (OFAC, March 2024), Ukraine (July 2025), the United Kingdom (May 2026) and the European Union (21st package, transaction ban effective August 2026). Authorities and blockchain analytics firms allege it facilitated Russian sanctions evasion, including transactions with Garantex, Hydra Market and sanctioned banks, systematic address rotation to defeat monitoring, and services to the A7 LLC network and its rouble-pegged A7A5 stablecoin, which Bitpapa lists.","sections":[{"content":"On March 25, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Bitpapa IC FZC LLC under Executive Order 14024 (the Russian Harmful Foreign Activities Sanctions program), as part of a package of 13 entities and two individuals sanctioned for allegedly helping build or operate blockchain-based services to facilitate Russian sanctions evasion. OFAC's designation states that \"Bitpapa IC FZC LLC (Bitpapa) operates a peer-to-peer virtual currency exchange and offers services to Russian nationals,\" and that the company had conducted transactions worth millions of dollars with OFAC-designated Russian entities Hydra Market (a darknet marketplace) and Garantex (a sanctioned crypto exchange). OFAC noted the platform had a documented history of transacting with sanctioned banks, cryptocurrency exchanges and darknet markets. Chainalysis and TRM Labs, citing on-chain analysis, reported that value sent by Bitpapa to sanctioned entities and darknet markets increased over the course of Russia's invasion of Ukraine.","heading":"U.S. OFAC Sanctions (March 2024)","sources":[{"url":"https://home.treasury.gov/news/press-releases/jy2204","name":"U.S. Treasury press release: Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology Procurement","type":"regulatory","credibility":1},{"url":"https://www.theblock.co/news/regulation/2024-03-25-us-treasury-sanctions-13-entities-for-aiding-russian-sanctions-evasion-via-crypto-284582","name":"The Block: OFAC sanctions 13 entities for aiding Russian sanctions evasion via crypto","type":"news_article","credibility":1},{"url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/","name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/us-treasurys-ofac-sanctioned-russia-based-crypto-exchanges-and-fintechs-for-facilitating-sanctions-evasion","name":"TRM Labs: US Treasury's OFAC sanctions Russia-based crypto exchanges and fintechs for facilitating sanctions evasion","type":"research","credibility":2},{"url":"https://www.cointrust.com/market-news/ofac-sanctions-russian-entities-including-netex24-and-bitpapa-facilitating-sanctions-evasion-via-blockchain-services","name":"OFAC Sanctions Russian Entities Including Netex24 and Bitpapa — CoinTrust","type":"news_article","credibility":2}],"severity":"critical"},{"content":"The primary alleged counterparties named in the OFAC designation are Garantex, the Russia-based exchange that was itself sanctioned by OFAC and shut down by law enforcement in March 2025, and Hydra Market, the darknet marketplace sanctioned by OFAC and taken down in 2022. Bitpapa is also alleged to have regularly transacted with Bitzlato, a previously seized and sanctioned exchange, and with sanctioned Russian banks including Sberbank and Alfa-Bank. Chainalysis identified alleged transactions with MOO Veche, an OFAC-designated pro-Russian militia organization operating in occupied Ukrainian territories, and with pro-Russian propaganda groups, and blockchain analysis further identified flows from Hydra successor markets including OMG!OMG!, Mega and Blacksprut passing through the platform. Reports differ on the share of Bitpapa's outbound flows going to sanctioned targets: one page in this record attributes to Chainalysis an estimate that approximately 9.7% of Bitpapa's outgoing cryptocurrency flows went to OFAC-sanctioned targets, with approximately 5% to Garantex, while the other found that percentage breakdowns vary across secondary reporting and could not be confirmed against a primary on-chain dataset. These figures should therefore be treated as approximate analytics estimates.","heading":"Alleged Transactions with Sanctioned Entities","sources":[{"url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/","name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/us-treasurys-ofac-sanctioned-russia-based-crypto-exchanges-and-fintechs-for-facilitating-sanctions-evasion","name":"TRM Labs: US Treasury's OFAC sanctions Russia-based crypto exchanges and fintechs for facilitating sanctions evasion","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/ofac-sanctions-enablers-of-russian-sanctions-evasion","name":"OFAC Sanctions Enablers of Russian Sanctions Evasion — Elliptic","type":"research","credibility":2},{"url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion","name":"Russia-linked Cryptocurrency Services and Sanctions Evasion — Elliptic","type":"research","credibility":2},{"url":"https://www.cointrust.com/market-news/ofac-sanctions-russian-entities-including-netex24-and-bitpapa-facilitating-sanctions-evasion-via-blockchain-services","name":"OFAC Sanctions Russian Entities Including Netex24 and Bitpapa — CoinTrust","type":"news_article","credibility":2}],"severity":"critical"},{"content":"OFAC and blockchain analytics firms have identified systematic address rotation as a central operational characteristic of Bitpapa's alleged sanctions evasion. According to OFAC's designation rationale as reported by Chainalysis, the platform manages its wallets by constantly rotating addresses, a technique alleged to prevent transaction monitoring systems from identifying Bitpapa as a counterparty and to obscure the Russian origin of funds from services that subsequently receive them. This alleged behavior distinguishes Bitpapa from exchanges that interact with sanctioned entities only incidentally, suggesting deliberate countermeasures against compliance screening. The UK's May 2026 sanctions introduced Regulation 17A obligations requiring UK-regulated firms not only to freeze direct counterparty funds but to trace transactions across multiple blockchain hops, which analysts describe as a novel mechanism aimed at the layering techniques attributed to platforms such as Bitpapa.","heading":"Alleged On-Chain Evasion Techniques","sources":[{"url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/","name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","credibility":2}],"severity":"critical"},{"content":"On July 6, 2025, Ukraine's National Security and Defense Council (NSDC) sanctioned Bitpapa IC FZC LLC under Ukraine's national sanctions law (Law of Ukraine \"On Sanctions\" No. 1644-VII), for a period running to July 6, 2035, as part of a broader decree targeting over 70 individuals and 60 companies accused of facilitating crypto-based sanctions evasion for Russia.","heading":"Ukraine Sanctions (July 2025)","sources":[{"url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/","name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","credibility":2},{"url":"https://decrypt.co/328876/ukraine-sanctions-russian-crypto-networks-crackdown-war-financing","name":"Ukraine Sanctions 70 People, 60 Companies Over Crypto Transactions — Decrypt","type":"news_article","credibility":2}],"severity":"critical"},{"content":"On May 26, 2026, the UK Foreign, Commonwealth and Development Office (FCDO) added Bitpapa IC FZC LLC to the UK Sanctions List (entry RUS3609) as part of a package designating 18 companies and individuals under the Russia (Sanctions) (EU Exit) Regulations 2019. The UK government characterized the action as the first time Britain had directly designated major cryptocurrency platforms under its Russia sanctions regime. According to the FCDO's stated reasons, the Secretary of State considered there to be \"reasonable grounds to suspect that Bitpapa is an involved person\" because it is or has been \"involved in obtaining a benefit from or supporting the Government of Russia by carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian financial services sector.\" Reporting indicated Bitpapa was accused of providing financial services, funds or economic resources to A7 Limited Liability Company. Measures imposed include an asset freeze, trust services sanctions, director disqualification, internet services sanctions (requiring UK-facing app stores, ISPs and platforms to restrict access to Bitpapa), correspondent banking sanctions, and a prohibition on UK financial institutions processing payments for or transferring funds to the company; the designation also brought the Regulation 17A multi-hop tracing obligation. Bitpapa was designated alongside other crypto and payment firms including HTX (formerly Huobi), Exmo Exchange Limited, Rapira Group LLC, Aifory LLC, ABCEX and Arvix, and entities tied to Garantex Europe. HTX was separately accused of channeling over $1.5 billion to Russia through flows to sanctioned entities.","heading":"UK FCDO Sanctions (May 2026)","sources":[{"url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","name":"GOV.UK: List of Russia sanctions designations, 26 May 2026","type":"regulatory","credibility":1},{"url":"https://search-uk-sanctions-list.service.gov.uk/designations/RUS3609/Entity","name":"UK Sanctions List entry for Bitpapa (RUS3609)","type":"regulatory","credibility":1},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","credibility":2},{"url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/","name":"BanklessTimes: UK Sanctions Bitpapa, Exmo and Others Over A7 Links","type":"news_article","credibility":2},{"url":"https://paymentexpert.com/2026/05/27/uk-sanctions-russia-crypto-payments/","name":"Payment Expert: UK sanctions Russia-linked A7 crypto and payment firms","type":"news_article","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2},{"url":"https://www.cryptotimes.io/2026/05/26/uk-moves-to-choke-russias-crypto-powered-shadow-economy/","name":"UK Moves to Choke Russia's Crypto-Powered Shadow Economy — CryptoTimes","type":"news_article","credibility":2}],"severity":"critical"},{"content":"The European Union listed Bitpapa as part of its 21st sanctions package against Russia, adopted by the Council of the EU in July 2026 and published in its Official Journal, with a transaction ban on Bitpapa and other listed platforms taking effect on August 23, 2026. Reporting indicates that following the EU action, major exchanges including Binance told users they would stop processing transactions involving Bitpapa and a group of other sanctioned crypto platforms. Bitpapa is consequently sanctioned under four separate national or supranational regimes (US, Ukraine, UK, EU), a pattern commentators and analysts at Chainalysis and TRM Labs have characterized as reflecting both the evasion capacity of P2P exchanges operating across jurisdictions and the limits of unilateral enforcement, alongside an emerging multilateral response.","heading":"European Union Sanctions (2026)","sources":[{"url":"https://cryptodaily.co.uk/2026/07/eu-crypto-sanctions-target-14-firms-russia","name":"CryptoDaily: EU Crypto Sanctions Target 14 Firms Linked to Russia","type":"news_article","credibility":2},{"url":"https://cryptoticker.io/en/eu-sanctions-crypto-platforms-transaction-ban/","name":"cryptoticker.io: EU Transaction Ban: 14 Crypto Platforms Blocked","type":"news_article","credibility":2},{"url":"https://www.elliptic.co/insights/crypto-regulatory-affairs-eu-adopts-new-russia-sanctions/","name":"Elliptic: Crypto regulatory affairs: EU adopts new Russia sanctions","type":"research","credibility":2},{"url":"https://coinpaprika.com/news/binance-freezes-out-htx-15-firms-eu-sanctions/","name":"Coinpaprika: Binance Freezes Out HTX and 15 Firms as EU Sanctions Bite","type":"news_article","credibility":2},{"url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/","name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2}],"severity":"critical"},{"content":"UK officials described A7 Limited Liability Company as a network \"designed to bypass Western sanctions, finance military procurement, and process funds from the sale of oil,\" and British authorities said it moved over $90 billion into Russia's economy in the prior year, a sum reportedly exceeding half of Russia's annual military budget. The network is alleged to route funds through foreign banks and digital asset platforms. Its primary instrument is the A7A5 stablecoin, a rouble-pegged token issued in Kyrgyzstan that researchers have linked to a sanctions-evasion network co-owned by Ilan Shor, a sanctioned Moldovan-Russian political figure, and Russian state-owned Promsvyazbank. A7A5 reportedly recorded approximately $93 billion in trading volume in its first year, mostly through exchanges with strong Russian ties, including Grinex (successor to Garantex) and Garantex itself; Chainalysis has separately estimated that tens of billions of dollars in sanctions-related flows have moved through the A7A5 wallet cluster and associated exchanges since launch, a figure describing the network as a whole rather than Bitpapa's share. Chainalysis identifies Bitpapa as one of the platforms on which A7A5 trading became available, with Bitpapa listing the token around mid-2025 and token trading volume increasing after its listing on P2P venues including Bitpapa. Bitpapa's own website advertises the ability to \"buy A7A5 for roubles with no fees.\" Available public sources do not establish a direct ownership link between Bitpapa and A7 LLC; the UK designation appears to reflect Bitpapa's alleged role as a facilitation node within the network rather than as an affiliated subsidiary.","heading":"A7 LLC Network and A7A5 Stablecoin","sources":[{"url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/","name":"Chainalysis: How A7A5 and Grinex Enable The Russian Shadow Crypto Economy","type":"research","credibility":2},{"url":"https://bitpapa.com/buy-a7a5","name":"Bitpapa: Buy A7A5 for roubles with no fees (bitpapa.com/buy-a7a5)","type":"official","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","credibility":2},{"url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/","name":"BanklessTimes: UK Sanctions Bitpapa, Exmo and Others Over A7 Links","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/business/2026/05/26/uk-sanctions-huobi-and-ruble-stablecoin-issuer-in-crackdown-on-russia-crypto-networks","name":"UK sanctions Huobi and Ruble Stablecoin Issuer in Crackdown on Russia Crypto Networks — CoinDesk","type":"news_article","credibility":2},{"url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","name":"GOV.UK: List of Russia sanctions designations, 26 May 2026","type":"regulatory","credibility":1},{"url":"https://paymentexpert.com/2026/05/27/uk-sanctions-russia-crypto-payments/","name":"Payment Expert: UK sanctions Russia-linked A7 crypto and payment firms","type":"news_article","credibility":2}],"severity":"high"},{"content":"Bitpapa operates a peer-to-peer marketplace where users post buy and sell offers for cryptocurrency against fiat currency. It is oriented toward Russian-speaking users in Russia, Ukraine, Belarus and Kazakhstan and supports rouble-denominated transactions, including via Russian banking and payment networks. Supported assets have included Bitcoin, Ethereum, USDT and other cryptocurrencies, and the platform also explored trading of a crypto-rouble instrument designated RUBT. Bitpapa markets itself as a zero-fee exchange. In a February 2026 report, Elliptic flagged Bitpapa as one of five cryptocurrency exchanges that had stepped into the vacuum left by the March 2025 shutdown of Garantex, acting as an informal fiat on-ramp for Russian users under sanctions pressure. Its position as a cash-to-crypto gateway for the Russian domestic market is central to its characterization by authorities as part of Russia's shadow financial infrastructure, and it has continued operating through multiple designations.","heading":"Platform Operations and Market Positioning","sources":[{"url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic","name":"Five Crypto Exchanges Are Helping Russia Evade Sanctions, Filling Garantex's Void — The Block","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/business/2026/02/23/elliptic-flags-russia-linked-crypto-platforms-ongoing-sanctions-evasion","name":"Elliptic Flags Russia-Linked Crypto Exchanges Over Sanctions Exposure Risks — CoinDesk","type":"news_article","credibility":2},{"url":"https://monetory.io/en/exchangers/platforms/bitpapa","name":"Monetory.io: P2P exchange BITPAPA","type":"other","credibility":3},{"url":"https://www.accessnewswire.com/newsroom/en/computers-technology-and-internet/bitpapa.com-announces-the-launch-of-its-digital-assets-trading-pla-709973","name":"Bitpapa.com Announces the Launch of Its Digital Assets Trading Platform — AccessNewswire","type":"other","credibility":3}],"severity":"high"},{"content":"Bitpapa IC FZC LLC was incorporated on April 29, 2022, with its registered address at A-0059-652 Flamingo Villas, Ajman Media City Free Zone, Ajman, UAE, UAE registration number 5069 and Economic Register Number (CBLS) 11874154. An alternate registration number, RA000693_172229, is associated with a Belize jurisdiction. The entity has operated under names including Bitpapa, Baba House LLC, Bitpapa FZC LLC, Bitpapa AiSi EfZetSi, Bitpapa Pay and Papa Holding Ltd, and maintains websites at bitpapa.com and bitpapa.org with contact email support@bitpapa.com. Its public launch announcement for a digital assets trading platform and mobile app dates to July 27, 2022. Reports differ on when the P2P service began: company profile aggregators place its founding in 2017 or 2018, while another reading of the Monetory.io profile reports operations beginning as early as May 2020; either way, the service predates the 2022 incorporation of the sanctioned legal entity. Chainalysis alleged that Bitfingroup OÜ, an Estonia-based company, is likely controlled by Timur Evgenyevich Bukanov, who also owns and directs TOEP (operating as Netex24/Netexchange), a separately sanctioned Russian entity, and characterized Bitpapa as likely controlled by Bukanov through this network. This connection is an analytical inference rather than a confirmed fact in public sources.","heading":"Corporate Structure and Alleged Control","sources":[{"url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/","name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","credibility":2},{"url":"https://finance.yahoo.com/news/bitpapa-com-announces-launch-digital-161500961.html","name":"Bitpapa.com Announces the Launch of Its Digital Assets Trading Platform — Yahoo Finance","type":"news_article","credibility":2},{"url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/","name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","credibility":2},{"url":"https://monetory.io/en/exchangers/platforms/bitpapa","name":"Monetory.io: P2P exchange BITPAPA","type":"other","credibility":3}],"severity":"medium"},{"content":"Bitpapa has received mixed user reviews on Trustpilot and other consumer review platforms. Multiple user complaints allege account freezes without explanation after funding, funds sent to counterparties that were never received, and support response times reportedly exceeding a year in some disputed cases. Some reviewers describe difficulty obtaining refunds or resolution from an offshore-registered company. Other aggregators, such as ScamAdviser, have rated the site as apparently legitimate based on automated website-trust signals. These are user-submitted, unverified reports and are noted as alleged consumer experiences rather than established fact.","heading":"User Complaints and Platform Reliability","sources":[{"url":"https://www.trustpilot.com/review/bitpapa.com","name":"Trustpilot: Bitpapa Reviews","type":"community_report","credibility":3},{"url":"https://www.scamadviser.com/check-website/bitpapa.com","name":"ScamAdviser: bitpapa.com Reviews","type":"community_report","credibility":3}],"severity":"medium"}],"timeline":[{"date":"2020-05","event":"Bitpapa reportedly begins operations as a peer-to-peer cryptocurrency exchange targeting Russian and CIS markets (approximate; other profiles place its founding in 2017 or 2018).","source":"Monetory.io platform profile","source_url":"https://monetory.io/en/exchangers/platforms/bitpapa"},{"date":"2022-02","event":"Russia invades Ukraine. Blockchain analytics later show Bitpapa's transactions with sanctioned entities increasing from this point.","source":"Chainalysis","source_url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/"},{"date":"2022-04-29","event":"Bitpapa IC FZC LLC incorporated in the UAE (Ajman Media City Free Zone), the legal entity later subject to sanctions designations.","source":"OpenSanctions entity profile","source_url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/","date_evidence":"Incorporation Date: April 29, 2022"},{"date":"2022-07","event":"Bitpapa IC FZC LLC publicly announces the launch of its digital assets trading platform and mobile application.","source":"Bitpapa.com launch announcement via Yahoo Finance","source_url":"https://finance.yahoo.com/news/bitpapa-com-announces-launch-digital-161500961.html"},{"date":"2024-03-25","event":"U.S. OFAC designates Bitpapa IC FZC LLC under Executive Order 14024 for allegedly facilitating millions of dollars in payments to OFAC-designated entities including Hydra Market and Garantex, and for allegedly rotating addresses to evade monitoring.","source":"U.S. Treasury press release","source_url":"https://home.treasury.gov/news/press-releases/jy2204","date_evidence":"Designation Date: March 25, 2024"},{"date":"2025-03","event":"Garantex, a primary alleged counterparty of Bitpapa, is shut down by law enforcement. Elliptic later identifies Bitpapa as one of five exchanges filling the vacuum in rouble-to-crypto services.","source":"The Block","source_url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic"},{"date":"2025-06","event":"Bitpapa reportedly begins listing the rouble-pegged A7A5 stablecoin, coinciding with a surge in the token's trading volume.","source":"Chainalysis","source_url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/"},{"date":"2025-07","event":"Ukraine's National Security and Defense Council sanctions Bitpapa IC FZC LLC (reported as July 6, 2025, running to July 6, 2035) as part of a decree targeting over 70 individuals and 60 companies for crypto-based sanctions evasion.","source":"Decrypt; OpenSanctions entity profile","source_url":"https://decrypt.co/328876/ukraine-sanctions-russian-crypto-networks-crackdown-war-financing"},{"date":"2026-02","event":"Elliptic publishes a report flagging Bitpapa and four other exchanges as filling the role previously occupied by Garantex in Russia's sanctions-evasion infrastructure.","source":"CoinDesk","source_url":"https://www.coindesk.com/business/2026/02/23/elliptic-flags-russia-linked-crypto-platforms-ongoing-sanctions-evasion"},{"date":"2026-05-26","event":"UK FCDO designates Bitpapa IC FZC LLC under the Russia (Sanctions) (EU Exit) Regulations 2019 alongside 17 other entities and individuals, including HTX and EXMO, for allegedly supporting Russian sanctions evasion via the A7 network; imposes asset freeze, correspondent banking, internet services and payment-processing restrictions.","source":"GOV.UK sanctions designation list","source_url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","date_evidence":"List of Russia sanctions designations, 26 May 2026"},{"date":"2026-07","event":"The Council of the European Union adopts its 21st sanctions package against Russia, including Bitpapa among the newly listed entities.","source":"CryptoDaily","source_url":"https://cryptodaily.co.uk/2026/07/eu-crypto-sanctions-target-14-firms-russia"},{"date":"2026-08","event":"Binance notifies users it will stop processing transactions involving Bitpapa and other EU-sanctioned crypto platforms.","source":"Coinpaprika","source_url":"https://coinpaprika.com/news/binance-freezes-out-htx-15-firms-eu-sanctions/"},{"date":"2026-08","event":"EU transaction ban on Bitpapa and other sanctioned platforms takes 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