Enforcement Actions Against Garantex: Money Laundering Techniques and Lessons Learned

A major cryptocurrency laundering scheme has been brought to an end in March 2025.

Garantex, a digital asset exchange active since 2019, was taken offline through a coordinated enforcement action led by the United States, Germany, and Finland. The figures behind this case are significant:

• Processed over $96 billion in cryptocurrency transactions in total.

• Hundreds of millions traced to ransomware, hacking, drug trafficking, and terrorism financing

• Continued operations after being sanctioned by the U.S. Treasury in April 2022

• Garantex did not register as a money transmitting business with FinCEN.

Why Garantex was taken down

This wasn’t a matter of oversight or weak internal controls. Garantex administrators knowingly enabled criminal activity and worked to conceal it. When the U.S. Treasury’s Office of Foreign Assets Control (OFAC) blacklisted the platform, Garantex didn’t stop. Instead, it redesigned operations specifically to evade sanctions and trick U.S. businesses into transacting with it, despite clear prohibitions.

Behind the scenes were Aleksej Besciokov, Garantex’s technical administrator, and Aleksandr Mira Serda, the exchange’s co-founder and chief commercial officer. Both now face charges for conspiracy to launder money, conspiracy to violate sanctions, and operating an unlicensed money transmitting business.

Sanctions Evasion and Money Laundering Techniques

The tactics they used to avoid detection reveal just how far illicit actors will go:

• Moved its operational cryptocurrency wallets to different addresses to complicate blockchain tracing

• Deceptive responses to law enforcement, including denying links to known accounts while submitting falsified or incomplete information

• Failure to register with FinCEN, despite clear U.S. operations and obligations

• Ongoing engagement with U.S. entities, even after being sanctioned

The consequences:

• The U.S. seized Garantex.org, Garantex.io, and Garantex.academy

• Over $26 million in associated crypto funds was frozen

• German and Finnish authorities seized servers used in Garantex’s operations

• The U.S. also accessed earlier backups of the platform’s data, including customer and accounting records

Lessons learned

So, what are the key lessons for the AML and compliance community? The Garantex case offers three critical lessons for the crypto industry and the broader financial ecosystem.

1. Do not attempt to bypass sanctions. Once OFAC imposed sanctions on Garantex in April 2022, all activity involving U.S. persons or infrastructure should have ceased immediately. Instead, the platform’s operators deliberately circumvented those restrictions and continued to transact with U.S.-based entities.

2. Do not ignore regulatory obligations. Garantex operated as a money transmitting business without registering with FinCEN. That decision was not an oversight - it was a strategic choice to avoid supervision. Any business established in any country must understand its regulatory obligations and take them seriously.

3. Understand evasion techniques to avoid exposure. Firms must be proactive in learning how illicit actors operate. The methods used by Garantex are not unique. These tactics continue to, not only evolve, but to become more sophisticated. Exchanges, financial institutions, and service providers must train their teams to recognize the signs of sanctions evasion.

The message from enforcement is clear: if you operate in crypto, you must build compliance into your foundation. Because ultimately, the cost of non-compliance will always outweigh the cost of getting it right.

If you’re unsure whether your crypto compliance program meets regulatory expectations, this is the time to check.

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