Sanctions lists change frequently. What was a safe business relationship yesterday may not be legitimate today. Financial regulators don’t accept ‘I didn’t know’ as an excuse, and getting caught doing business with a sanctioned entity can result in frozen accounts, legal trouble, and reputational damage. 

A real-world example? Here’s just one. On February 5, 2025, Israel’s National Bureau for Counter Terror Financing has ordered the seizure of crypto wallets and client accounts of the Dubai Company for Exchange, also known as El-kahira for General Trading. In the document, officials claim the company has been providing “substantial assistance” to Hamas and is classified as a designated terrorist organization. 

The list includes 58 wallet addresses on TRON. The first recorded activity on the “earliest” wallet dates back to Feb 8, 2021, and from that point until now, these addresses have received 160 million USDT. 

GL Counterparty report for 58 wallet addresses sanctioned by NBCTF ordered by amount, from highest to lowest 

As the report shows, about 59 million USDT (37% of funds) were received by low-risk exchanges, and over 50.7 million USDT (31.9%) went to medium-risk exchanges. These include top-tier entities, registered in:

• Malta — 58.4 million USDT (36.7%)
• Seychelles — 20.5 million USDT (12.89%) 
• Cayman Islands — 9.07 million USDT (5.7%). 

As for risky sources, the top three include sanctioned exchanges (2.9 million USDT) and wallets (222,300 USDT) and addresses connected to terrorism financing (343,971 USDT). Notably, over 2.8 million USDT were received from and more than 1.5 million USDT were transferred to Garantex. This is significantly less than the amount received by the top three low- and medium-risk entities. 

GL Counterparty report for 58 wallet addresses sanctioned by NBCTF ordered by risk level, from highest to lowest

During the period after the introduction of sanctions, the transaction volume amounted to 57,507 USDT, with over 98% of these funds coming from low-risk exchanges. However, these funds were not used, as Tether blocked the wallets at the smart contract level. 

GL Counterparty report for 58 wallet addresses after sanctions implementation

At the time of writing, a remaining balance of approximately 600,000 USDT is still in these wallets. After Tether blocked the wallets, funds can still be deposited but not withdrawn.

Final thoughts

In this case, Tether blocked addresses, and funds were not used. However, the risk isn’t always obvious—until it’s too late. Even post-sanctions, over 56 million USDT came from low-risk platforms. 

Are you sure you are not on the list? Don’t leave it to chance. Let us help you verify your business partners and ensure compliance before it’s too late!