Сделки крипто 2025: как защитить ваши стейблкоины от рисков

Guide: How to Protect Your Stablecoins from Freezing

Legal Disclaimer: This article is for informational purposes only and does not constitute financial or legal advice. Cryptocurrency operations involve high risks. Consult with a qualified lawyer or financial advisor before making decisions.

TL;DR: Summary

Self-Custody: Keep your main capital on hardware wallets (Ledger, Trezor) or multisig wallets (Safe). Do not keep large sums on exchanges.
Vet Counterparties: Use AML services (even free ones) to check addresses before receiving funds.
Diversify: Distribute assets across different stablecoins (USDC, USDT), exchanges, and wallets.
Segregate Flows: Maintain separate wallets for CEX trading, DeFi, and long-term storage. Do not mix them.
Be KYC/AML Ready: Keep documents proving the origin of your funds (bank statements, contracts, tax returns).
Avoid "Red Flags": Do not use mixers, do not receive funds from suspicious addresses, and do not interact with sanctioned services.

Introduction: Who Should Read This and Why

Increased regulatory scrutiny of stablecoins has turned the risk of asset freezing from hypothetical to real. This article is a practical guide for private investors, traders, and businesses using stablecoins (USDT, USDC, etc.) for savings, settlements, or trading operations.

We will look at the two main freezing scenarios:

Issuer-Level Freeze: When Tether or Circle blocks an address at the request of authorities.
Exchange-Level Freeze (CEX): When a platform blocks an account due to suspicions of AML policy violations.

By reading this guide, you will get a step-by-step action plan and a toolkit to minimize risks, as well as learn what to do if your assets are already frozen.

1. Freezing Levels: Issuer vs. Exchange

Issuer-Level Freeze

Tether (USDT) and Circle (USDC) have a "blacklist" function built into their token smart contracts. This allows them to block any address upon request from law enforcement agencies (e.g., the US DOJ or Europol). A frozen address cannot send or receive stablecoins from that issuer.

Example: In November 2023, Tether froze $225 million in USDT linked to a criminal group.

Exchange-Level Freeze

Centralized exchanges (CEX) are required to comply with KYC/AML procedures. Their automated systems may flag your account as suspicious and temporarily block it. The reason could be receiving funds from an address linked to mixers, sanctioned services, or fraud. In this case, all assets on the exchange account are blocked.

2. Step 1: Check Addresses (AML Screening)

Before any transaction, especially when receiving funds, verify the counterparty's address.

How to Check an Address on Etherscan (and Similar Explorers)

Copy the counterparty's address.
Paste it into the search bar on a block explorer (e.g., Etherscan.io).
Examine the address page:
- Labels: Look for labels like "Tornado Cash," "OFAC Sanctioned," or "Scam." These are direct indicators of extremely high risk.
- Transaction History: Look at where funds are coming from and going to. If the address is directly linked to mixers or sanctioned services, decline the transaction.

How to Check for Blocking in the Smart Contract (USDT Example)

Go to the USDT contract page on Etherscan.
Open the Contract tab, then Read Contract.
Find the isBlacklisted function.
Paste the address you want to check and click Query.
A result of true means the address is blocked.

AML Services Comparison

Service	Free Version	Paid Version	Suitable For
AMLBot, GetBlock	A few free checks, basic risk score %	Detailed reports, risk source analysis, API integration	Private users for occasional checks
Chainalysis, TRM Labs	Usually none (business demos only)	Deep analysis, monitoring, investigations, used by CEX	Large businesses, funds, exchanges

For private use, free versions are sufficient for basic hygiene.

3. Step 2: Use Self-Custody and Diversify Storage

The principle "not your keys, not your coins" applies 100% here.

Hardware Wallets (Ledger, Trezor)

Store private keys offline. Ideal for long-term storage.

Step-by-step setup:

Buy the device from an official dealer.
Generate a new seed phrase (24 words) upon first use.
Write the phrase down on paper (not digitally!) and hide it in a secure place.
Set a PIN code on the device.
To withdraw to an exchange: send a small test transaction first.

Multisig Wallets (Safe, formerly Gnosis Safe)

Require multiple signatures for a transaction, protecting against a single point of failure.

Basic Safe setup:

Go to safe.global and connect your wallet (e.g., MetaMask).
Click Create new Safe and select the network.
Add Owner addresses — these can be different hardware wallets.
Set the signature threshold (e.g., 2 out of 3). This means confirming a transaction requires signatures from two of the three owner wallets.
Securely save the seed phrases for all owner wallets in different locations.

Storage Configurations

Small sums (<$10,000): Hardware wallet.
Medium sums ($10,000–$100,000): Safe multisig wallet with a 2-of-3 threshold (e.g., two hardware wallets + one software wallet as a backup).
Large sums (>$100,000): Distributed 3-of-5 multisig with wallets stored in different geographic locations, or use of professional custodial services.

4. Step 3: Consider Jurisdictional Risks

USA: OFAC has global reach. Any interaction with sanctioned addresses carries a risk of blocking, regardless of your citizenship.
EU: The MiCA regulation introduces strict rules for stablecoin issuers, including reserve requirements and blocking procedures. This increases transparency but also tightens control.
Other Jurisdictions (including CIS): Uncertain regulation means you depend on the rules of the exchange's or issuer's jurisdiction. Legal protection may be difficult in case of problems.
Dual Citizenship: Use documents from the jurisdiction where regulation is clearer, but remember your obligations to all countries of your citizenship.

Legal Mechanisms: In case of an exchange block, study the Terms of Service. They usually provide for an internal appeal procedure or arbitration. Litigation is an extreme and expensive measure.

5. Technical Risks During Transfers

Bridges: When transferring a stablecoin from one network to another (e.g., USDC from Ethereum to Polygon), you use a bridge, which can be hacked. Furthermore, if "dirty" assets passed through the bridge, it could create risk for your funds.
Wrapped Tokens: A wrapped token (e.g., soETH) is not the original asset but its "representation" in another network, issued by a third-party contract. It carries the risks of both the bridge and the issuing contract.
DeFi Interaction: Using unverified DeFi protocols, especially those that have been hacked, can "taint" your address as risky for exchange AML systems.

6. What NOT To Do: Major Prohibitions

Do not use mixers (Tornado Cash and similar). This is the fastest way to get blocked on any regulated platform.
Do not accept funds from unknown persons, especially large sums in P2P deals, without vetting their addresses first.
Do not try to hide or deceive the exchange regarding the origin of funds. This will undermine trust and complicate unblocking.
Do not keep all funds on one exchange or in one stablecoin.

7. What to Do If Your Funds Are Already Frozen?

Determine the Level of the Freeze: Is the exchange account frozen, or are transactions failing from a non-custodial wallet?
Contact Exchange Support: Write a polite and clear email.

Support Email Template:

Subject: Urgent: Inquiry regarding locked account (ID: [Your ID] / Email: [Your Email])

Dear Support Team at [Exchange Name],

Today, [Date], I discovered that my account has been locked (or my funds frozen). I am unable to [describe the issue: withdraw funds, trade, etc.].

I have been a client since [Year] and have always followed platform rules. My last operation was [describe last operation].

Please inform me of the reason for the block and the steps I need to take to resolve this issue. I am ready to provide all necessary documents to confirm the legality of my funds.

Sincerely,
[Your Name]

Prepare Documents (Source of Funds/Wealth):
- General: Bank statements confirming fiat deposits to exchanges; tax returns; salary certificates.
- Crypto: Statements from other exchanges showing trading history; data from block explorers confirming income from staking, DeFi, or P2P deals.
- Business/Investments: Sales contracts, loan agreements, inheritance documents, or dividend records.
Consult a Lawyer: If the amount is significant and support does not respond or refuses without valid reasons, consult a lawyer specializing in cryptocurrencies.

Conclusion

It is impossible to completely eliminate regulatory risks, but proper management is key to asset preservation. A proactive approach, including AML hygiene, diversification, and the use of self-custody solutions, significantly reduces the likelihood of facing a freeze.

Useful Links and Resources

MiCA Regulation: Official Text
Circle Blocking Policy (USDC): Criteria on Circle's site
Tether Documentation: Transparency and Reports
Safe Multisig Wallet: Official Site
Etherscan Explorer: Tool for transaction analysis.

Crypto Industry Deals 2025: Stablecoin Protection Guide