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{"actor":"system:backfill","investigation_id":"cd48afbc-cd12-410f-a21e-ee9027b5cd8c","kind":"publish","page_slug":"bitpapa-exchange","published_at":"2026-09-18T23:28:19.670Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"Bitpapa Exchange","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, 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). 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, and that Bitpapa regularly interacted with Bitzlato, a previously seized and sanctioned exchange, and reportedly facilitated transactions for MOO Veche, an OFAC-designated pro-Russian militia group. Specific percentage breakdowns of Bitpapa's outbound transaction volume vary across secondary reporting and could not be independently confirmed against a primary on-chain dataset, so no precise percentage figure is asserted here.","heading":"U.S. OFAC Sanctions (March 2024)","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury press release: Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology Procurement","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy2204"},{"credibility":1,"name":"The Block: OFAC sanctions 13 entities for aiding Russian sanctions evasion via crypto","type":"news_article","url":"https://www.theblock.co/news/regulation/2024-03-25-us-treasury-sanctions-13-entities-for-aiding-russian-sanctions-evasion-via-crypto-284582"},{"credibility":2,"name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/"},{"credibility":2,"name":"TRM Labs: US Treasury's OFAC sanctions Russia-based crypto exchanges and fintechs for facilitating sanctions evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/us-treasurys-ofac-sanctioned-russia-based-crypto-exchanges-and-fintechs-for-facilitating-sanctions-evasion"}]},{"content":"On May 26, 2026, the UK Foreign, Commonwealth and Development Office (FCDO) added Bitpapa IC FZC LLC to the UK Sanctions List as part of a package designating 18 companies and individuals under the Russia (Sanctions) (EU Exit) Regulations 2019. According to the FCDO's stated reasons for designation, 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 on the designation indicated Bitpapa was accused of providing financial services, funds, or economic resources to A7 Limited Liability Company, a network UK officials described as \"designed to bypass Western sanctions, finance military procurement, and process funds from the sale of oil.\" 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. Bitpapa was designated alongside other crypto and payment firms including HTX (Huobi), EXMO, Rapira Group, Aifory, ABCEX, and Arvix, and alongside entities tied to Garantex Europe, as part of the same alleged evasion network.","heading":"UK FCDO Sanctions (May 2026)","severity":"critical","sources":[{"credibility":1,"name":"GOV.UK: List of Russia sanctions designations, 26 May 2026","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":1,"name":"UK Sanctions List entry for Bitpapa (RUS3609)","type":"regulatory","url":"https://search-uk-sanctions-list.service.gov.uk/designations/RUS3609/Entity"},{"credibility":2,"name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"credibility":2,"name":"BanklessTimes: UK Sanctions Bitpapa, Exmo and Others Over A7 Links","type":"news_article","url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/"},{"credibility":2,"name":"Payment Expert: UK sanctions Russia-linked A7 crypto and payment firms","type":"news_article","url":"https://paymentexpert.com/2026/05/27/uk-sanctions-russia-crypto-payments/"}]},{"content":"Bitpapa has also been designated under Ukraine's national sanctions law (Law of Ukraine \"On Sanctions\" No. 1644-VII) beginning around July 2025, and by the European Union as part of its 21st sanctions package against Russia, adopted in the Council of the EU's Official Journal, with a transaction ban on Bitpapa and other listed platforms taking effect 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 now sanctioned under four separate national or supranational regimes (US OFAC, Ukraine, UK, EU), a pattern commentators have characterized as reflecting the limits of unilateral sanctions enforcement against P2P exchanges operating outside the jurisdictions imposing the sanctions.","heading":"Ukraine and European Union Sanctions","severity":"critical","sources":[{"credibility":2,"name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/"},{"credibility":2,"name":"cryptoticker.io: EU Transaction Ban: 14 Crypto Platforms Blocked","type":"news_article","url":"https://cryptoticker.io/en/eu-sanctions-crypto-platforms-transaction-ban/"},{"credibility":2,"name":"Elliptic: Crypto regulatory affairs: EU adopts new Russia sanctions","type":"research","url":"https://www.elliptic.co/insights/crypto-regulatory-affairs-eu-adopts-new-russia-sanctions/"},{"credibility":2,"name":"Coinpaprika: Binance Freezes Out HTX and 15 Firms as EU Sanctions Bite","type":"news_article","url":"https://coinpaprika.com/news/binance-freezes-out-htx-15-firms-eu-sanctions/"},{"credibility":2,"name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"}]},{"content":"Chainalysis research on the A7A5 stablecoin — a rouble-pegged token 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 — 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 following its listing on P2P venues including Bitpapa. Bitpapa's own website independently advertises the ability to \"buy A7A5 for roubles with no fees,\" confirming the platform's role as an on/off-ramp for the token. Chainalysis has estimated that tens of billions of dollars in sanctions-related flows have moved through the A7A5 wallet cluster and associated exchanges since the token's launch, though this figure describes the network as a whole rather than Bitpapa's individual share.","heading":"A7A5 Stablecoin and Broader Evasion Network","severity":"high","sources":[{"credibility":2,"name":"Chainalysis: How A7A5 and Grinex Enable The Russian Shadow Crypto Economy","type":"research","url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/"},{"credibility":2,"name":"Bitpapa: Buy A7A5 for roubles with no fees (bitpapa.com/buy-a7a5)","type":"official","url":"https://bitpapa.com/buy-a7a5"}]},{"content":"Independent of the sanctions actions, Bitpapa has received a mix of 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 as an offshore-registered company. Other review aggregators, such as ScamAdviser, have rated the site as apparently legitimate based on automated website-trust signals. These complaints are drawn from user-submitted reviews (a lower-credibility source category) and have not been independently verified; they are noted here as alleged, unverified consumer experiences rather than established fact, and should be weighted accordingly.","heading":"User Complaints and Platform Reliability","severity":"medium","sources":[{"credibility":3,"name":"Trustpilot: Bitpapa Reviews","type":"community_report","url":"https://www.trustpilot.com/review/bitpapa.com"},{"credibility":3,"name":"ScamAdviser: bitpapa.com Reviews","type":"community_report","url":"https://www.scamadviser.com/check-website/bitpapa.com"}]},{"content":"Corporate registry aggregation shows Bitpapa IC FZC LLC was incorporated on April 29, 2022, with registrations in the United Arab Emirates (Ajman Media City Free Zone) and Belize, and has operated under alternate names including Baba House LLC, Bitpapa FZC LLC, Bitpapa AiSi EfZetSi, Bitpapa Pay, and Papa Holding Ltd. Company profile aggregators place Bitpapa's founding as a P2P trading platform in 2017 or 2018, prior to the 2022 incorporation of the currently sanctioned legal entity, serving primarily Russia, Ukraine, Belarus, and Kazakhstan.","heading":"Corporate Structure","severity":"low","sources":[{"credibility":2,"name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/"},{"credibility":3,"name":"Monetory.io: P2P exchange BITPAPA","type":"other","url":"https://monetory.io/en/exchangers/platforms/bitpapa"}]}],"sources_used":[{"credibility":1,"name":"U.S. Treasury press release: Treasury Designates Russian Companies Supporting Sanctions Evasion Through Virtual Asset Services and Technology Procurement","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy2204"},{"credibility":1,"name":"The Block: OFAC sanctions 13 entities for aiding Russian sanctions evasion via crypto","type":"news_article","url":"https://www.theblock.co/news/regulation/2024-03-25-us-treasury-sanctions-13-entities-for-aiding-russian-sanctions-evasion-via-crypto-284582"},{"credibility":1,"name":"GOV.UK: List of Russia sanctions designations, 26 May 2026","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":1,"name":"UK Sanctions List entry for Bitpapa (RUS3609)","type":"regulatory","url":"https://search-uk-sanctions-list.service.gov.uk/designations/RUS3609/Entity"},{"credibility":2,"name":"TRM Labs: UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"credibility":2,"name":"TRM Labs: US Treasury's OFAC sanctions Russia-based crypto exchanges and fintechs for facilitating sanctions evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/us-treasurys-ofac-sanctioned-russia-based-crypto-exchanges-and-fintechs-for-facilitating-sanctions-evasion"},{"credibility":2,"name":"Chainalysis: OFAC Sanctions Netex24 and Bitpapa, Plus Other Russian Crypto Companies","type":"research","url":"https://www.chainalysis.com/blog/ofac-sanctions-russia-blockchain-companies-netex24-bitpapa/"},{"credibility":2,"name":"Chainalysis: How A7A5 and Grinex Enable The Russian Shadow Crypto Economy","type":"research","url":"https://www.chainalysis.com/blog/a7a5-grinex-russian-crypto-economy-ofac-sanctions-august-2025/"},{"credibility":2,"name":"BanklessTimes: UK Sanctions Bitpapa, Exmo and Others Over A7 Links","type":"news_article","url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/"},{"credibility":2,"name":"Payment Expert: UK sanctions Russia-linked A7 crypto and payment firms","type":"news_article","url":"https://paymentexpert.com/2026/05/27/uk-sanctions-russia-crypto-payments/"},{"credibility":2,"name":"OpenSanctions: Bitpapa IC FZC LLC entity profile","type":"research","url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/"},{"credibility":2,"name":"Elliptic: Crypto regulatory affairs: EU adopts new Russia sanctions","type":"research","url":"https://www.elliptic.co/insights/crypto-regulatory-affairs-eu-adopts-new-russia-sanctions/"},{"credibility":2,"name":"cryptoticker.io: EU Transaction Ban: 14 Crypto Platforms Blocked","type":"news_article","url":"https://cryptoticker.io/en/eu-sanctions-crypto-platforms-transaction-ban/"},{"credibility":2,"name":"Coinpaprika: Binance Freezes Out HTX and 15 Firms as EU Sanctions Bite","type":"news_article","url":"https://coinpaprika.com/news/binance-freezes-out-htx-15-firms-eu-sanctions/"},{"credibility":2,"name":"CryptoDaily: EU Crypto Sanctions Target 14 Firms Linked to Russia","type":"news_article","url":"https://cryptodaily.co.uk/2026/07/eu-crypto-sanctions-target-14-firms-russia"},{"credibility":2,"name":"Bitpapa: Buy A7A5 for roubles with no fees (bitpapa.com/buy-a7a5)","type":"official","url":"https://bitpapa.com/buy-a7a5"},{"credibility":3,"name":"Trustpilot: Bitpapa Reviews","type":"community_report","url":"https://www.trustpilot.com/review/bitpapa.com"},{"credibility":3,"name":"ScamAdviser: bitpapa.com Reviews","type":"community_report","url":"https://www.scamadviser.com/check-website/bitpapa.com"},{"credibility":3,"name":"Monetory.io: P2P exchange BITPAPA","type":"other","url":"https://monetory.io/en/exchangers/platforms/bitpapa"}],"summary":"Bitpapa (legally Bitpapa IC FZC LLC, also doing business as Baba House LLC and Papa Holding Ltd) is a UAE-registered peer-to-peer cryptocurrency exchange serving primarily Russian, Ukrainian, Belarusian, and other CIS-region users. It has been designated under sanctions programs in four separate jurisdictions — the United States (OFAC, March 2024), Ukraine (July 2025), the United Kingdom (May 2026), and the European Union (2026, effective August 2026) — each alleging that Bitpapa facilitated Russian sanctions evasion, including transactions with darknet markets and sanctioned banks and exchanges. The platform also independently lists the rouble-pegged A7A5 stablecoin, which researchers have linked to a sanctions-evasion network tied to a sanctioned political figure and a state-owned Russian bank.","timeline":[{"date":"2022-04-29","date_evidence":"Incorporation Date: April 29, 2022","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":"2024-03-25","date_evidence":"Designation Date: March 25, 2024","event":"U.S. OFAC designates Bitpapa IC FZC LLC under Executive Order 14024 for allegedly facilitating sanctions evasion via transactions with Hydra Market and Garantex.","source":"U.S. Treasury press release","source_url":"https://home.treasury.gov/news/press-releases/jy2204"},{"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 Defence Council designates Bitpapa under Ukrainian sanctions law.","source":"OpenSanctions entity profile","source_url":"https://www.opensanctions.org/entities/NK-7FnYMCu6yNkVmhKnLJ9qRw/"},{"date":"2026-05-26","date_evidence":"List of Russia sanctions designations, 26 May 2026","event":"UK FCDO designates Bitpapa IC FZC LLC 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":"2026-07","date_original":"2026-07-23","event":"The Council of the European Union adopts its 21st sanctions package against Russia, including Bitpapa among the newly listed entities.","source":"CryptoDaily / VASPnet reporting on EU 21st sanctions package","source_url":"https://cryptodaily.co.uk/2026/07/eu-crypto-sanctions-target-14-firms-russia"},{"date":"2026-08","date_original":"2026-08-14","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","date_original":"2026-08-23","event":"EU transaction ban on Bitpapa and other sanctioned platforms takes effect.","source":"cryptoticker.io","source_url":"https://cryptoticker.io/en/eu-sanctions-crypto-platforms-transaction-ban/"}]},"v":1}