Sanctions Evasion Reference

TGR Group: cash in one city, USDT in another

Treasury designated a network in 2024 that moved value for Russian elites by pairing bulk cash handovers against transfers of dollar-referenced stablecoins, settling the two against each other.

period

2023–2024

outcome

Designation

parties

TGR Group; George Rossi; Elena Chirkinyan; Ekaterina Zhdanova; TGR Corporate Concierge LTD

programmes

Russian Federation

reviewed

2026-08-20

Designated on 4 December 2024 under Executive Order 14024. The most useful published description of what stablecoin settlement actually looks like in operation — which is not what the phrase suggests.

Who was designated

Individuals: George Rossi, a Ukrainian national; Elena Chirkinyan, a Russian national; Andrejs Bradens, a Latvian national; Khadzi-Murat Magomedov and Nikita Krasnov, Russian nationals.

Entities: TGR Partners in Moscow, TGR Corporate Concierge LTD in the United Kingdom, TGR DWC- LLC in the United Arab Emirates, and Siam Expert Trading Company Limited in Thailand. Pullman Global Solutions LLC, a Wyoming company more than fifty per cent owned by Bradens, was identified as blocked property.

Treasury describes the group as an “extensive sanctions evasion and money laundering network” that obfuscates its clients’ activities “including through the use of digital assets, such as stablecoins like Tether (USDT).”

The mechanism, which is hawala with a new settlement leg

The sentence that matters: Chirkinyan and other members “arranged cash handovers in which USDT was sent to a cryptocurrency address controlled by Zhdanova, and in return cash was received by the TGR Group.”

Read that carefully. Nothing crossed a border. One party transferred a stablecoin on a public ledger; another party handed over physical cash somewhere else; the two obligations cancelled.

That is the structure described on the [hawala page](/techniques/hawala-and-informal-value- transfer/), with one substitution. Traditional settlement between brokers happens later, in aggregate, through reverse flows, trade invoices or gold. Here the settlement asset is a dollar-referenced token, and it settles in minutes.

The advantage over the traditional version is speed and finality. The cash leg still has all the problems cash has — it is bulky, it has to be physically moved, and Magomedov and Zhdanova are recorded as arranging “international bulk cash deliveries and the conversion of bulk currency into cryptocurrency for clients.”

Why stablecoins specifically

A commercial obligation is denominated in dollars. Settling it in a volatile asset gives one side a currency position it did not ask for. A fiat-referenced token removes that, which is the entire reason this instrument, rather than bitcoin, appears in the commercial settlement material.

The corporate and trade layers

The network is not purely digital, and that is the point. TGR Corporate Concierge is a corporate services company, and Treasury records that the group likely used it “to facilitate invoice payments, monetary transfers and/or cash for USDT transactions.” Krasnov and Zhdanova are recorded as using a luxury watch company for trade-based money laundering.

Company formation, invoices, watches, bulk cash and stablecoins, in one network. Practitioners do not specialise the way technique pages do, and this designation is a good reminder of it.

Zhdanova

Ekaterina Zhdanova, who led the Smart Group, was designated separately on 3 November 2023 and coordinated extensively with TGR. The two designations are best read together.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Russia sanctions — Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.
  • United Arab Emirates — A major re-export hub and financial centre that appears in enforcement records across almost every technique on this site, principally because of the volume of trade that passes through it.

Enforcement documents and sources

  1. Treasury Exposes Money Laundering Network Using Digital Assets to Evade Sanctions. U.S. Department of the Treasury, 2024. Press release jy2735, 4 December 2024.
  2. Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers. Financial Action Task Force, 2021.
  3. The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing. Financial Action Task Force, 2013.
  4. Sanctions Compliance Guidance for the Virtual Currency Industry. U.S. Department of the Treasury, Office of Foreign Assets Control, 2021.
  5. Trade-Based Money Laundering: Trends and Developments. Financial Action Task Force and Egmont Group, 2020.

All enforcement cases