Secondary sanctions and export controls in the crypto economy: how digital assets fall under extraterritorial control and who bears the risks

This report analyzes secondary sanctions and export restrictions in the context of the cryptocurrency economy. It examines how extraterritorial sanctions regimes extend to operations with digital assets, infrastructure intermediaries, and users who are not residents of sanctioning states. Particular attention is given to enforcement mechanisms through private platforms, the role of “facilitators,” risks for international trade in digital services, and consequences for legal certainty and financial autonomy.