The U.S. the U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 22 individuals and 104 entities operating in 20 countries for their role in facilitating Russian sanctions evasion, including John Desmond Hanafin, Founder of Dubai based Huriya Private, a fintech firm, who has an active Ethereum address included as an identifier on his SDN List entry.

Hanafin is the founder and CEO of Huriya Private FZE LLE, a Dubai-based financial services company also sanctioned today for its role in funneling Russian funds into the UAE. 

According to OFAC’s press release, Hanafin in his role at Huriya has been working since the outset of the Russia-Ukraine War to help Russian nationals protect their assets from sanctions. Much of this activity has involved helping Russian nationals move their money into UAE bank accounts and obtain fraudulent passports. 

As per Chainalysis blog, John Hanafin’s on-chain transactions may shed light on Huriya’s Russian sanctions evasion operations.

OFAC included a single Ethereum address as an identifier on Hanafin’s SDN list entry. That address is 0x38735f03b30FbC022DdD06ABED01F0Ca823C6a94. Since becoming active in January 2022, that address has received roughly $4.9 million worth of cryptocurrency, mostly in Tether (USDT).

According to Chainalysis article, across the 75 USDT transactions received by Hanafin, there were several in amounts with following ranges  $5,000 – $10,000, $15,000 – $25,0000, $100,000 – $150,000.

Chainalysis included some examples of transaction within those ranges on Chainalysis Reactor graph.

While Chainalysis states that they cannot be sure that any of the payments to Hanafin’s wallet reflect citizenship by investment purchasing, they do point out, “ it certainly appears possible given this is a service Huriya offers, and Hanafin’s work acquiring false passports for Russian nationals as described by OFAC.”

Chainalysis adds, “ As for the high-frequency payments to Hanafin’s wallet that came in smaller amounts, it’s possible that those were related to lower-cost services Huriya offers, such as establishment of UAE bank accounts or corporate structuring.”

Chainalysis explains that while crypto may still play a role in Russian sanctions evasion, the transparency of blockchain means that blockchain analysis combined with open source data can open up valuable avenues for investigation.