Mikhail Uspenskiy

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Compliance and sanctions risk

Assisting bank compliance on operations involving digital assets, analysing the sanctions aspects of crypto transactions, and drafting internal AML/KYC documents for market participants. Practice at the intersection of banking control, sector regulation and cross-border structures.

Banking

Support for bank compliance

Preparing positions and documents for banking control of digital-asset operations: economic rationale, source of funds, settlement structure.

Requests

Responses to bank requests

Supporting responses to credit institutions’ requests on cryptocurrency and stablecoin operations — from one-off queries to systemic interaction design.

Sanctions

Sanctions analysis

Assessing the sanctions aspects of operations and structures: counterparties, settlement chains, infrastructure. Identifying pinch points before a bank or counterparty does.

AML/KYC

AML/KYC documentation

Drafting internal policies and procedures for crypto exchangers, payment intermediaries and other market participants — taking into account exchange-operator requirements under Law No. 282-FZ.

Questions

Common questions

The bank has requested documents on crypto transactions — what to do?
Do not answer “as best one can”: the quality of the first response largely determines the outcome. A coherent position is needed — the economic rationale of the transactions, evidence of the source of funds, and a correct legal frame. Forming that position is a typical practice task.
What are the risks of ignoring a bank request?
Refusal to process transactions, termination of the banking relationship, and appearance in interbank information resources, which complicates banking elsewhere. Respond quickly and substantively.
What is support for bank compliance?
Work on the client’s side preparing documents and positions that enable the bank to take a positive decision on the transactions. This is not “circumventing” control, but correctly packaging lawful activity.
Which market participants need AML/KYC policies?
Above all digital-currency exchange operators, to whom Law No. 282-FZ applies requirements, as well as payment intermediaries and projects working with foreign infrastructure. Internal documents are a condition both for register entry and for durable banking relationships.
How to assess sanctions risk on a specific deal?
By checking every element: parties, beneficial owners, settlement infrastructure, subject matter. The outcome is either confirmation of permissibility or a redesign of the structure.
Do sanctions restrictions apply to cryptocurrency settlements?
Sanctions regimes cover operations with digital assets as well; blockchain anonymity does not protect against consequences. Sanctions analysis is therefore a mandatory part of structuring cross-border operations.
Can compliance be set up preventively, before banking problems arise?
Yes, and that is the optimal scenario: an audit of current operations, preparation of standard document packs, process design. Preventive work is many times cheaper than unblocking already stopped transactions.
Do you work with non-resident structures?
Yes: the practice covers structures in friendly jurisdictions and engagement with foreign intermediaries. More in the section International structuring.
Next

Related areas — cross-border settlements and international structuring. Complex mandates with Parallax.

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