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The Grey Corridor

Chainlabs Staff
March 3, 2026

Sanctions evasion, OTC layers & compliance implications for VASPs

March 3 2026

Recent financial restrictions in the Middle East follow a pattern established by earlier measures against sanctioned jurisdictions. The 2012 removal of Iranian banks from SWIFT set a template for coordinated exclusion from global financial infrastructure. Since that point, the Financial Action Task Force has extended its guidance to virtual asset service providers, focusing on risks associated with sanctions evasion and related illicit finance typologies.

Across the dataset, as formal financial channels narrow, higher-risk activity shifts into informal and opaque networks. Iranian entities, excluded from correspondent banking, SWIFT, and formal remittance systems, now rely on alternative mechanisms that operate outside established compliance controls.

Chainlabs' address-attribution and entity-clustering data indicate that hundreds of Iranian over-the-counter entities are operating across the Middle East, Europe, and Asia. These entities maintain links to global cryptocurrency exchanges. Some access centralised exchanges such as KuCoin and CoinEx directly; others transact through intermediaries. In both cases, OTC actors form part of a broader exchange-connected ecosystem that standard datasets do not capture.

Direct and indirect relationships between OTC entities and exchanges create persistent compliance blind spots. The gap often emerges at onboarding. Exchange KYC procedures typically identify the immediate counterparty but do not detect beneficial owners or affiliated entities behind OTC structures. Intermediary operators use lightly verified corporate accounts, generic documentation, or jurisdictional fragmentation to obscure both the origin of funds and the nature of account relationships.

Exchange-level controls are circumvented through incomplete identity verification, limited source-of-funds assessment, and insufficient monitoring of related accounts. Identifying these vulnerabilities enables compliance and risk teams to strengthen onboarding, apply enhanced due diligence to high-risk intermediaries, and implement more adaptive transaction monitoring. These dynamics shift as regional conflicts intensify and sanctions are imposed and lifted. Actors using these channels adapt their methods and redirect financial flows in response.

Implications for Compliance Teams

Exchange-level transaction monitoring does not capture the full scope of activity within the OTC layer. Actors seeking to evade controls use this less visible segment to access global liquidity outside established compliance frameworks. Effective compliance requires attribution methods that extend beyond wallet labelling.

Systematic mapping of relationships among entities, intermediaries, and exchange infrastructure, supported by verifiable source evidence, enables compliance teams to assess anonymous crypto activity before formal sanctions designations are issued. The dataset covers hundreds of cash-desk operations worldwide, each linked to exchange infrastructure and supported by provenance data. We deliver this intelligence via API, data feeds, and cloud platforms, integrating it directly into compliance, analytics, and risk systems. This helps organisations strengthen risk assessment and investigative workflows with reliable, continuously refreshed data.

Chainlabs Know who is behind crypto flows