Three Enforcement Gaps
What the UK's May 26, 2026 sanctions package did not reach
Gap 1
OFAC
US has not acted
The UK designated ABCeX. OFAC has not. OFAC designated Bitpapa (Mar 2024) with less documented evidence. ABCeX meets the same criteria by every available metric.
Gap 2
AEXBit
Successor not designated
TRM Labs' co-spending analysis indicates common control with ABCeX. Same wallets, same Telegram channels. Not named in the UK designation — not as entity, not as alias.
Gap 3
Paysol
Payment layer untouched
The payment agent that bridges the crypto ecosystem to Russian banks. CEO holds active California contractor's license. Wallets interacted with sanctioned Garantex addresses. Not designated by any government.
The UK's May 26 package was the most comprehensive crypto-sanctions action any Western government has assembled. It still missed the successor, the US enforcement arm, and the payment layer.
Source: OFAC SDN, UK FCDO (May 26, 2026), TRM Labs, OCCRP. CrimsonVector 2026.