From 25 August 2026, as part of its 21st sanctions package against Russia, the EU has expanded an existing restriction on crypto-asset businesses: Russian nationals and people residing in Russia (already barred from owning, controlling or holding board positions in EU crypto wallet, account and custody providers) will be banned from doing so across all crypto-asset services, as defined under the EU's Markets in Crypto-Assets Regulation (MiCA).
This measure sits alongside a significant tightening of the EU's crypto-related sanctions regime. Transaction bans have been extended to fourteen crypto-related service platforms based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus, and the Council of the EU has introduced a new legal mechanism allowing it to impose a full transaction ban on crypto asset service providers and trading platforms established in any third country found to be persistently undermining EU sanctions.
Will the UK follow suit?
Despite the UK and EU's broadly aligned stance on Russia sanctions since 2022, there's no indication yet that the UK plans to introduce an equivalent board and ownership ban of its own. Crucially, the UK is under no legal obligation to replicate EU sanctions measures and operates its own independent regime under the Sanctions and Anti-Money Laundering Act 2018, with designations made separately from the EU.
The UK has tended to follow the EU's lead on Russia-related sanctions, but typically with a delay - sometimes weeks, sometimes months - and there's no guarantee any given EU measure gets mirrored at all. Rather than blanket nationality-based restrictions, the UK's crypto-focused sanctions to date have taken a more targeted approach, designating specific platforms and networks implicated in sanctions evasion.
Whether the UK ultimately adopts a comparable board membership restriction remains to be seen. For the time being, the gap between the EU's new rule and any UK equivalent leaves a notable divergence that firms operating across both jurisdictions must navigate.
How will this affect your firm?
Crypto-asset businesses with an EU nexus should establish whether the expanded restriction applies to their ownership and governance arrangements. In particular, firms should consider the following:
Ownership and governance - Are your beneficial ownership structures and governance arrangements demonstrably compliant with the expanded EU rule?
Screening depth - Do your onboarding and periodic review processes capture nationality and residency status at board and controller level, not just at the customer level?
Cross-jurisdictional tracking - If you operate across both the EU and UK, are you tracking the two regimes separately, or assuming an alignment that doesn't exist?
And for all firms, it is worth thinking ahead - given the UK's tendency to follow EU sanctions with a lag, would you be prepared for a similar measure to land in the UK later this year?
The restriction is principally concerned with ownership, control and governance. Firms should therefore prioritise those relationships, while ensuring that their wider sanctions screening remains proportionate to the risks presented by customers, counterparties, suppliers and other third parties.
How FINTRAIL and Cosegic can help
FINTRAIL and Cosegic advise crypto-asset businesses on exactly these challenges, combining deep sector knowledge of the crypto industry with specialist sanctions expertise. We support firms in: Assessing exposure - reviewing ownership, control and governance structures against the EU's expanded restrictions and against UK designations, to identify any gaps
Strengthening screening and monitoring - ensuring sanctions screening extends beyond transactions to ownership, board composition, and beneficial control
Navigating cross-jurisdictional divergence - building compliance frameworks that account for the EU and UK's separate regimes, rather than assuming alignment where none exists
Preparing for future measures - helping firms anticipate likely regulatory developments rather than respond to them after the fact
With the 25 August deadline now effective, the priority for affected firms shifts from preparation to demonstrable compliance. If you have not yet completed a full review of your ownership, control and governance structures against the expanded restrictions, this should be treated as a matter of urgency rather than a routine exercise. If you would like support assessing your current position, remediating any gaps, or establishing ongoing monitoring to stay ahead of future measures, we would be pleased to help.