USDT в Венесуэле: защита активов

Amidst hyperinflation and economic sanctions, the USDT stablecoin has become a key tool for savings and commercial settlements for many Venezuelans. However, its centralized nature creates significant risks. This article is intended for private users and small businesses in Venezuela. Its goal is to dissect the mechanism of asset freezing by the issuer, Tether, and offer practical steps to minimize risks. We will examine the technical specifics of blockings across different networks, distinguish between custodial and non-custodial scenarios, and provide a step-by-step checklist for safe P2P transactions.

1. Context: Oil, Sanctions, and Tether’s Reaction

The proliferation of USDT in Venezuela is closely linked to the oil and gas sector. To bypass US sanctions, the state-owned company PDVSA began using stablecoins, primarily on the Tron network (TRC-20), to settle export deliveries [3]. This, combined with mass cryptocurrency adoption by the general population, has made Venezuela a leader in P2P trading volume in Latin America [2] and attracted the attention of international law enforcement agencies.

The issuer of USDT, Tether, has adopted a stance of active cooperation with regulators, manifested in systemic blocking of addresses linked to illicit activity.

Key Facts About USDT Freezes:

• Total Volume: As of mid-2024, Tether has frozen assets totaling over $1.3 billion on addresses linked to sanctions evasion, fraud, and terrorist financing. These figures are confirmed by reports from analytical firms and Tether's official statements [1].
• Cooperation with US Authorities: In December 2023, Tether announced a collaboration with the US Secret Service and the FBI, resulting in the blocking of 31 addresses holding $225 million linked to an international human trafficking ring [5].
• Systemic Approach: Tether is a member of the T3 Financial Crime Unit (FCU) alliance alongside Tron and the analytics firm TRM Labs to proactively detect and block illicit transactions [6].

2. Technical Aspect: How and Where Freezing Occurs

2.1. The Blocking Mechanism in Smart Contracts

The ability to freeze USDT is not a function of the blockchain itself, but a function hardcoded by the issuer into the token's smart contract. This means Tether retains administrative control over USDT on all networks where it is officially issued.

• On EVM-compatible blockchains (Ethereum, Polygon, BSC, Avalanche): The USDT smart contract (ERC-20 standard) contains the functions addBlackList(address _user) and destroyBlackFunds(address _blackListedUser). Once an address is added to the blacklist, any attempt to make outgoing transactions from it will be rejected at the contract level. Link to the contract on Ethereum: Etherscan.
• On the Tron network (TRC-20): The smart contract has a similar function: addBlackList(address _user). Link to the contract: Tronscan.
• Other networks (Omni, Solana, Algorand): The mechanism is implemented at the protocol level or via native smart contracts, but the result is the same—Tether retains the ability to freeze funds on any address.

Important: Using a non-custodial wallet (e.g., MetaMask, Trust Wallet, Ledger) protects your private keys, but it does not protect against token freezing at the smart contract level. You remain the owner of the address, but the USDT on it becomes "immobile."

2.2. Custodial vs. Non-Custodial Scenarios

It is critically important to understand who can initiate a freeze and how, depending on where the funds are stored.

Non-Custodial Scenario (Your Personal Wallet):

• Who blocks: Only the issuer (Tether) upon request from law enforcement.
• How it works: Your address is directly added to the USDT smart contract blacklist. Funds are frozen on the address, and you cannot move them.

Custodial Scenario (Funds on an Exchange):

• Who blocks: Primarily the exchange itself (the custodian). Secondarily, Tether.

• How it works:

  1. Exchange Freeze: If your activity on the exchange appears suspicious (e.g., receiving funds from a risky address), the exchange may freeze your account in accordance with its AML policy. This is the most common cause of blockings.
  2. Issuer Freeze: Tether may block one of the exchange's main hot wallets if it is proven that the entire platform is being used for illegal activity. This is a rare but possible event that would affect all users of that exchange.

• Cross-Chain Bridges: When transferring USDT via official bridges (e.g., Ethereum to Polygon), you are still using an asset controlled by Tether. The risk of freezing remains. When using unofficial bridges, the risk shifts to the bridge itself—if its liquidity pools are frozen, your funds may also end up locked.

3. Comparison of USDT with Alternatives

Despite the risks, USDT's dominance in Venezuela is explained by its high liquidity and network effect. Let’s look at alternatives based on key metrics.

Stablecoin	Issuer	Regulatory Risk	Liquidity in Venezuela (P2P)	On-chain freeze support	Speed / Fees
USDT	Tether	High. Active cooperation with regulators.	Very High. The standard for P2P trading on Binance P2P and local platforms.	Yes	Network dependent (TRC-20: low, ERC-20: high)
USDC	Circle	Very High. US issuer, fully subject to US law.	Moderate. Present, but volumes are significantly lower than USDT.	Yes	Network dependent (similar to USDT)
DAI	MakerDAO	Low/Medium. Decentralized, no single issuer to block addresses. Risk tied to potential freezing of collateral (e.g., USDC in reserve).	Low. Difficult to find counterparties for direct exchange to bolivars or USD.	No (direct function)	Only on EVM networks (high fees on Ethereum)

4. Practical Guide to Risk Minimization

It is impossible to completely eliminate risk, but it can be significantly reduced.

Step 1. Asset Diversification

Do not keep all funds in USDT. Consider an allocation: for example, 60% in USDT for operational liquidity, 20% in USDC, and 20% in DAI or physical dollars to reduce centralization risk. Use different blockchains (Tron, Polygon, BSC).

Step 2. Counterparty Checklist (AML Screening)

Before receiving funds, especially in P2P transactions exceeding $200, you must check the sender's address.

1. Request the address. Ask the counterparty to provide the exact address from which the funds will be sent before the transaction.
2. Use an AML service. Paste the address into one of the available services: AMLBot, GetBlock AML, Btrace. Most offer a few free checks.
3. Analyze the result. The report will show:
   • Risk Score (%): The general risk rating of the address.
   • Source of Funds: Links to exchanges, mixers, darknet, sanctioned wallets.
4. Make a decision based on "Red Flags":
   • Risk Score > 70%: Most services consider this high risk. It is recommended to decline the deal. This is not a strict law, but an industry standard for caution.
   • Direct links to high-risk categories: If the fund sources explicitly mention Sanctions, Darknet Service, Mixer, Scam, or Stolen Funds — refuse the deal immediately, even if the overall risk percentage is low.
5. Act. If the address is risky, politely inform the counterparty that you cannot accept funds from that address due to security reasons and ask them to use a different, "clean" wallet.

Case Study (Anonymized): A small business in Caracas importing electronics received a USDT payment of $5,000 from a new client abroad. No AML check was performed. Two weeks later, the company's operational wallet was frozen by Tether. Subsequent analysis showed the funds came from an address linked to a sanctioned entity. Despite appeals to Tether support, the funds were not unblocked as the freeze was initiated by law enforcement request. The loss was $5,000. Conclusion: A preventive check could have saved the capital.

Step 3. Maintaining "Digital Hygiene"

• Separate Wallets: Use a hardware wallet (Ledger, Trezor) for long-term storage and a separate "hot" (mobile) wallet for P2P transactions.
• Don't Mix Streams: Never transfer funds directly from a "hot" P2P wallet to your main "cold" wallet. This can "taint" your clean savings.
• Legal Risk of "Cleaning" via Exchanges: Attempting to deposit "dirty" USDT onto a KYC-verified exchange to withdraw them is a bad strategy. Exchange AML systems can easily detect such funds, leading to the blocking of your exchange account and a potential report to regulators. This can be construed as money laundering.

5. Legal Context: International and Local Risks

Users in Venezuela are under double pressure.

• International Risks: The primary risk comes from OFAC (US Office of Foreign Assets Control). Any transaction directly or indirectly linked to sanctioned individuals or entities (including certain Venezuelan state structures) is grounds for an immediate block by Tether.
• Local Risks (Venezuela): Despite a lenient attitude toward cryptocurrencies, legislation in Venezuela remains unstable. The National Superintendency of Cryptoassets (SUNACRIP) has broad powers. Large or suspicious transactions may attract the attention of local authorities, creating a risk of investigation or asset confiscation at the local level.

Disclaimer: These recommendations are intended to protect bona fide users. They do not constitute legal advice. For handling large sums and establishing compliance procedures, consult lawyers specializing in digital assets and sanctions law.

6. Conclusion: Action Plan for Different Users

In the new reality where stablecoins are tightly integrated with the global financial system, proactive asset protection is a basic skill.

• Private Users: Diversify savings (USDT, DAI, cash dollars). Always use the AML checklist for P2P deals over $200.
• Small Business: Implement mandatory AML screening of all incoming payments as part of the operational process. Use separate wallets for working capital and profits.
• Large Companies and Exporters: It is necessary to build full compliance procedures involving professional solutions (e.g., Chainalysis, TRM Labs) and legal support. Using USDT for large settlements without compliance carries unacceptably high risks.

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Sources

1. Tether. (2023). Tether Freezes Over $1 Billion with Law Enforcement. [Based on official press releases and data aggregated by analytical platforms].
2. Chainalysis. (2023). The 2023 Geography of Cryptocurrency Report.
   https://www.chainalysis.com/geography-of-cryptocurrency-2023/
3. Reuters. (2024). Venezuela amps up crypto payments for oil exports to evade US sanctions.
   https://www.reuters.com/technology/venezuela-amps-up-crypto-payments-oil-exports-evade-us-sanctions-2024-04-22/
4. Tether. (2024). Tether’s Q1 2024 Attestation.
   https://tether.to/en/tethers-q1-2024-attestation-highlights-record-breaking-452b-profit-and-1137b-in-us-treasury-exposure/
5. U.S. Department of Justice. (2023). U.S. Secret Service Investigation Leads to Seizure of $225M in Cryptocurrency Tied to International Romance Scam.
   https://www.secretservice.gov/newsroom/releases/2023/12/us-secret-service-investigation-leads-seizure-225m-cryptocurrency
6. TRM Labs. (2023). Tether, Tron, and TRM Labs Launch "T3" Financial Crime Unit.
   https://www.trmlabs.com/post/tether-tron-and-trm-labs-launch-t3-financial-crime-unit
7. Etherscan. Tether USD (USDT) Contract Code.
   https://etherscan.io/token/0xdac17f958d2ee523a2206206994597c13d831ec7#code
8. Tronscan. Tether USD (USDT) Contract Code.
   https://tronscan.org/#/token20/TR7NHqjeKQxGTCi8q8ZY4pL8otSzgjLj6t/code