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On Tuesday this week, the UK designated HTX (Huobi), Exmo, Rapira, ABCex, and several A7-linked entities as part of a sanctions package targeting crypto networks used to evade UK sanctions on Russia. HTX is one of the five largest exchanges in the world; no crypto venue at this scale has been sanctioned before.

This webinar convenes sanctions and compliance experts from TRM for a practical discussion on implications and considerations for compliance teams. While the forward-looking compliance response is likely straightforward, especially for firms that already operate direct and indirect rules against designated entities, the lookback question is more complex. Transactions involving these entities that were not prohibited at the time now sit as potential predicates to money laundering under POCA. For firms beginning to scope what a risk-based bulk lookback should look like at HTX volume, questions on segmentation, materiality, resourcing and sequencing must be carefully considered.

This session is intended for sanctions officers, MLROs, and senior compliance and risk leaders and will serve as a forum to share information and perspective. It is not offered as legal, regulatory, or compliance advice.
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Head of Compliance Advisory at TRM Labs
Prior to joining TRM Labs, Tom served as the Head of Financial Crime Compliance Digital Assets at Goldman Sachs. In this capacity, he led the strategic efforts to build the bank’s first dedicated financial crime compliance team covering blockchain-based assets, and served in an advisory capacity across a number of business verticals including investment banking, private wealth, asset management, global markets and additional digital asset projects.

With a decade of experience working on anti-money laundering and related compliance issues at Goldman Sachs, he also led Transaction Surveillance teams, and served as Head of the Financial Intelligence Unit and Forensics Group teams.
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Head of Policy, EMEA, TRM Labs
Prior to joining TRM Labs, Ms. Chase led a research cluster on Financial Crime Futures at Royal United Services Institute (RUSI), which was tasked with assessing the role of technology in compliance, evolving AML and CFT policy frameworks and how inclusive financial integrity can be achieved.

Having dedicated her career thus far to researching innovative policy responses to financial crime, Ms. Chase brings with her to TRM an intricate understanding of the UK and EU regulatory frameworks around financial crime.
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Compliance Advisor, EMEA, at TRM Labs
As Compliance Advisor at TRM Labs, Luke Dufour helps financial institutions, banks, and crypto-native businesses strengthen compliance programs and manage crypto-related risk. He most recently served as Deputy Money Laundering Reporting Officer at BVNK, a global virtual asset payments firm, where he led the Financial Crime Intelligence function. With deep expertise spanning financial crime intelligence, compliance, and public-private collaboration, Luke has also held roles at ClearBank, Barclays, and MoneyGram. Throughout his career, he has contributed to industry initiatives such as the UK National Crime Agency’s Joint Money Laundering Intelligence Taskforce and has consistently bridged the gap between traditional finance and virtual assets.
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Senior Blockchain Intelligence Analyst
Kiera Sibřina serves as a Senior Blockchain Intelligence Analyst on TRM's Blockchain Intelligence Team, where she is responsible for the collection and investigation of sanctioned actors. In this role, Kiera also publishes analysis on sanctions evasion and illicit finance activity across the cryptocurrency ecosystem. Prior to joining TRM, she worked as a compliance analyst at a Compliance-as-a-Service firm and at the U.S. Financial Crimes Enforcement Network (FinCEN), where she focused on investigating wildlife trafficking and terrorism financing.
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