The Garantex-Grinex-A7A5 lineage is the canonical worked example. Garantex Europe OÜ was incorporated under Estonian licensing in 2019 and operated as a high-throughput crypto-fiat exchange. Estonia's Financial Intelligence Unit revoked the license in February 2022 after AML/CFT deficiencies and confirmed wallet-overlap with criminal-use addresses. Treasury's April 5 2022 OFAC designation (`[ofac2022garantex]`), issued the same day as the Hydra Market designation, cited Garantex transactions linked to Conti ransomware (\~\$6M direct), Hydra (\~\$2.6M), and a broader \$100M+ illicit-flow surface. Garantex continued operating from Russia post-designation. Per `[treasury2025garantexnetwork]`, between April 2019 and March 2025 the exchange processed at least \$96B in total cryptocurrency volume, and post-2022 it built infrastructure intended to *prevent* downstream financial institutions from attributing wallet addresses back to Garantex — an explicit anti-attribution operational posture. The DOJ indictment unsealed February 27 2025 (`[doj2025garantex]`) named two administrators (Besciokov, Lithuanian national, primary technical administrator; Mira Serda, Russian national, co-founder and CCO). On March 6 2025 a coordinated U.S. Secret Service / German BKA / Finnish NBI action seized three Garantex domains and servers and froze \~\$26M in cryptocurrency. Besciokov was arrested in Kerala, India on March 12 2025 at U.S. request. Garantex officers created Grinex as a successor exchange immediately after the March 6 action; Treasury's August 14 2025 round designated Grinex and the A7A5 ruble-backed stablecoin network, characterising A7A5 as a sanctions-evasion vehicle processing \~\$1B daily.
0 commit comments