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{"actor":"system:backfill","investigation_id":"db9c3546-d7b7-482f-89a9-2cd437744da8","kind":"publish","page_slug":"tsunami-payments-llc","published_at":"2026-10-31T12:23:58.314Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Tsunami Payments LLC","sections":[{"content":"On 8 October 2026, the UK Foreign, Commonwealth & Development Office (FCDO) added Tsunami Payments LLC (also styled LLC Tsunami Payments, Russian: ООО «Цунами Пейментс») to the UK Sanctions List as part of a package of 38 Russia-related designations. The listing was made under the Russia (Sanctions) (EU Exit) Regulations 2019. The UK's stated rationale, per OpenSanctions' record of the FCDO entry and corroborating reporting, was alleged support for Russia's financial services sector; the measures include an asset freeze, an internet services restriction (requiring social media platforms, internet access providers and app stores to take reasonable steps to block UK users' access to the company's online content), and prohibitions on UK institutions maintaining correspondent banking relationships with it or processing payments through it. The underlying FCDO notice does not publicly detail specific transactions or evidence behind the designation.","heading":"UK Sanctions Designation","severity":"high","sources":[{"credibility":1,"name":"OpenSanctions entity record for Tsunami Payments LLC (UK FCDO listing)","type":"regulatory","url":"https://opensanctions.org/entities/gb-fcdo-rus3763"},{"credibility":2,"name":"UK Sanctions Cryptomus, Heleket, and TokenSpot in New Russia Package Targeting Crypto and Payment Channels","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-sanctions-cryptomus-heleket-and-tokenspot-in-new-russia-package-targeting-crypto-and-payment-channels"},{"credibility":2,"name":"UK blacklists Cryptomus, Heleket and TokenSpot over Russia links","type":"news_article","url":"https://crypto.news/uk-blacklists-cryptomus-heleket-and-tokenspot-over-russia-links/"},{"credibility":2,"name":"Interfax report on UK sanctions package naming Tsunami Payments","type":"news_article","url":"https://interfax.com/newsroom/top-stories/119470/"}]},{"content":"Tsunami Payments LLC is registered in Kyrgyzstan under registration number 227048-3301-ООО, with a listed address of Office 402, Tower B, 125/1 Toktogul Street, Bishkek. Multiple sources, including TRM Labs and crypto.news, report that this address places Tsunami in the same office tower as fellow UK-designee TokenSpot (listed at Office 1006 of the same building), a company TRM assesses as a front for the sanctioned exchange Grinex. TRM Labs' reporting, citing June 2024 Kyrgyz press articles (Kaktus, Aqparat) that in turn cited Kyrgyzstan's Justice Ministry registry, named Melis Batyrbekovich Umarhodjaev as director of both Tsunami Payments and TokenSpot at that time, and noted he no longer appeared in the registry as of September 2026. However, Interfax's October 2026 reporting states that, per Kyrgyz Justice Ministry data, Tsunami Payments' director was Kenzhebek Takyrbashev and its founder was Yulia Kuznetsova. These two accounts of Tsunami's leadership conflict and could not be reconciled from available sources; this is flagged as a lower-confidence detail pending a primary registry check. No independent reporting reviewed directly links Tsunami Payments to the A7 network or the A7A5 stablecoin, unlike Processing KG/VexPay, which TRM and other reporting tie more directly to that network.","heading":"Corporate Profile and Shared Address with TokenSpot","severity":"medium","sources":[{"credibility":2,"name":"UK Sanctions Cryptomus, Heleket, and TokenSpot in New Russia Package Targeting Crypto and Payment Channels","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-sanctions-cryptomus-heleket-and-tokenspot-in-new-russia-package-targeting-crypto-and-payment-channels"},{"credibility":2,"name":"UK blacklists Cryptomus, Heleket and TokenSpot over Russia links","type":"news_article","url":"https://crypto.news/uk-blacklists-cryptomus-heleket-and-tokenspot-over-russia-links/"},{"credibility":2,"name":"Interfax report on UK sanctions package naming Tsunami Payments","type":"news_article","url":"https://interfax.com/newsroom/top-stories/119470/"},{"credibility":1,"name":"OpenSanctions entity record for Tsunami Payments LLC","type":"regulatory","url":"https://opensanctions.org/entities/gb-fcdo-rus3763"}]},{"content":"Kyrgyz business outlet economist.kg reported on 24 June 2024 that Kyrgyzstan's National Bank had issued Tsunami Payments ('Цунами Пейментс') two licenses as a payment system operator. Interfax's October 2026 reporting on the sanctions package describes these as a license to process and clear third-party payments and settlements, and a separate license to accept and execute payments and settlements for goods and services via payment systems, both issued in 2024. These licenses indicate Tsunami operated, at least nominally, as a regulated Kyrgyz payment-processing entity prior to its UK designation; no source reviewed indicates the licenses have been revoked.","heading":"Kyrgyz Payment-System Licensing","severity":"medium","sources":[{"credibility":2,"name":"Нацбанк выдал две лицензии платежной системе «Цунами Пейментс» (National Bank issues two licenses to payment system Tsunami Payments)","type":"news_article","url":"https://economist.kg/novosti/2024/06/24/natsbank-vydal-dvie-litsienzii-platiezhnoi-sistiemie-tsunami-pieimients/"},{"credibility":2,"name":"Interfax report on UK sanctions package naming Tsunami Payments","type":"news_article","url":"https://interfax.com/newsroom/top-stories/119470/"}]},{"content":"TRM Labs, a blockchain analytics and compliance firm, published a research note in the same week as the UK designation naming Tsunami Payments alongside Cryptomus, Heleket, TokenSpot and Processing KG as entities newly added to the UK Sanctions List in connection with alleged Russia-related financial sanctions evasion. The note is aimed at financial institutions and compliance teams assessing counterparty exposure to the designated entities; it is a private research firm's analysis rather than a government finding, and should be read as such.","heading":"TRM Labs Compliance Advisory","severity":"medium","sources":[{"credibility":2,"name":"UK Sanctions Cryptomus, Heleket, and TokenSpot in New Russia Package Targeting Crypto and Payment Channels","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-sanctions-cryptomus-heleket-and-tokenspot-in-new-russia-package-targeting-crypto-and-payment-channels"}]},{"content":"Tsunami Payments' designation is part of a broader pattern of UK sanctions actions against Kyrgyz-registered financial and payment entities alleged to assist Russia in evading Western sanctions. Reporting cited by Interfax notes earlier UK designations of Kyrgyz-linked entities, including Keremet Bank (February 2025), Capital Bank of Central Asia and the exchanges Grinex and Meer (20 August 2025), and Eurasian Savings Bank, OJSC State Brokerage Company and OJSC Virtual Assets Issuer, issuer of the USDKG stablecoin (May 2026). In the same week as the Tsunami designation, Kyrgyzstan's Economy and Commerce Ministry reportedly announced plans to liquidate 51 legal entities over sanctions-related risk, and reports said Kyrgyzstan had decided to discontinue the USDKG stablecoin. These form the backdrop against which Tsunami Payments was designated but do not themselves establish specific wrongdoing by Tsunami.","heading":"Wider Context: UK's Kyrgyzstan-Focused Sanctions Campaign","severity":"medium","sources":[{"credibility":2,"name":"Interfax report on UK sanctions package naming Tsunami Payments","type":"news_article","url":"https://interfax.com/newsroom/top-stories/119470/"},{"credibility":2,"name":"UK sanctions crypto exchanges over suspected Russia-linked evasion","type":"news_article","url":"https://news.bitcoin.com/uk-sanctions-crypto-exchanges-over-suspected-russia-linked-evasion/"}]}],"sources_used":[{"credibility":1,"name":"OpenSanctions entity record for Tsunami Payments LLC (UK FCDO listing)","type":"regulatory","url":"https://opensanctions.org/entities/gb-fcdo-rus3763"},{"credibility":1,"name":"OpenSanctions entity record for OJSC Processing KG (UK FCDO listing)","type":"regulatory","url":"https://opensanctions.org/entities/gb-fcdo-rus3756"},{"credibility":2,"name":"UK Sanctions Cryptomus, Heleket, and TokenSpot in New Russia Package Targeting Crypto and Payment Channels","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-sanctions-cryptomus-heleket-and-tokenspot-in-new-russia-package-targeting-crypto-and-payment-channels"},{"credibility":2,"name":"UK blacklists Cryptomus, Heleket and TokenSpot over Russia links","type":"news_article","url":"https://crypto.news/uk-blacklists-cryptomus-heleket-and-tokenspot-over-russia-links/"},{"credibility":2,"name":"Interfax report on UK sanctions package naming Tsunami Payments","type":"news_article","url":"https://interfax.com/newsroom/top-stories/119470/"},{"credibility":2,"name":"UK sanctions crypto exchanges over suspected Russia-linked evasion","type":"news_article","url":"https://news.bitcoin.com/uk-sanctions-crypto-exchanges-over-suspected-russia-linked-evasion/"},{"credibility":2,"name":"Нацбанк выдал две лицензии платежной системе «Цунами Пейментс» (National Bank issues two licenses to payment system Tsunami Payments)","type":"news_article","url":"https://economist.kg/novosti/2024/06/24/natsbank-vydal-dvie-litsienzii-platiezhnoi-sistiemie-tsunami-pieimients/"}],"summary":"Tsunami Payments LLC is a Bishkek, Kyrgyzstan-registered payment-processing company that was added to the UK Sanctions List on 8 October 2026 as part of a 38-target package targeting alleged Russia sanctions-evasion networks. The UK cited alleged support for Russia's financial services sector; reporting also notes Tsunami shared an office building with fellow-designee TokenSpot, though sources disagree on who its director and founder actually are, and no independent reporting directly ties Tsunami to the A7/A7A5 network.","timeline":[{"date":"2024-06","event":"Kyrgyzstan's National Bank issues Tsunami Payments two licenses as a payment system operator, per Kyrgyz business press.","source":"economist.kg","source_url":"https://economist.kg/novosti/2024/06/24/natsbank-vydal-dvie-litsienzii-platiezhnoi-sistiemie-tsunami-pieimients/"},{"date":"2026-09","event":"Kyrgyzstan's Justice Ministry registry no longer lists Melis Batyrbekovich Umarhodjaev as a director, per TRM Labs' review of the registry.","source":"TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/uk-sanctions-cryptomus-heleket-and-tokenspot-in-new-russia-package-targeting-crypto-and-payment-channels"},{"date":"2026-10-08","date_evidence":"UK FCDO Sanctions List ... Start date: 2026-10-08","event":"The UK FCDO adds Tsunami Payments LLC to the UK Sanctions List as part of a 38-target Russia-related package, alongside Processing KG, TokenSpot and others.","source":"OpenSanctions (UK FCDO listing)","source_url":"https://opensanctions.org/entities/gb-fcdo-rus3763"},{"date":"2026-10","date_original":"2026-10-09","event":"Interfax and TRM Labs report on the UK designation of Tsunami Payments, Processing KG, TokenSpot and associated individuals.","source":"Interfax","source_url":"https://interfax.com/newsroom/top-stories/119470/"}]},"v":1}