The $205 Million Volume Dispute: How TRM Labs and Elliptic Exposed A7A5 Stablecoin's Wash Trading

Evidence Elliptic Cites

Elliptic's analysis tells a similar story, with an emphasis on just how much A7A5's activity has collapsed under the weight of Western sanctions:

• 90%+ decline. Elliptic co-founder Tom Robinson stated that monthly transaction volumes have fallen by more than 90% since January 2026 and are down 96% from their peak in 2025, following sanctions from the U.S., EU, and UK, and the collapse of the Grinex exchange .
• The figures are "cherry-picked." Robinson said the trading figures provided by A7A5 "conceal the obvious trend: that A7A5 is failing in its goal of enabling Russian sanctions evasion" .
• Elliptic's broader reporting tracked A7A5 crossing $100 billion in total on-chain transactions in its first year, but emphasized its primary use was internal book-settling and migrating frozen assets between sanctioned entities, not organic third-party trading .

A7A5's Defense

A7A5's director for regulatory affairs, Oleg Ogienko, denies the claims. He argues that because most A7A5 activity takes place in decentralized finance (DeFi) — where trades occur directly between wallets without centralized exchange intermediation — it is not fully captured by major data sites like CoinMarketCap, CoinGecko, and DeFiLlama, which he claims rely too heavily on centralized exchange data. He characterized their methodology as "a generally discriminatory approach, contrary to the principles of the United Nations" .

Broader Context: Crypto-Enabled Sanctions Evasion

This controversy highlights several systemic trends that go far beyond a data methodology quarrel:

A state-backed sanctions-evasion architecture

A7A5 is not a rogue project. Its reserves are held at Russia's sanctioned defense bank Promsvyazbank, and it was created by the A7 network — co-owned by Promsvyazbank and sanctioned Moldovan oligarch Ilan Shor — specifically to process cross-border payments for Russian companies excluded from SWIFT and the formal banking system .

From Garantex to Grinex to A7A5

After the March 2025 multinational takedown of the sanctioned Garantex exchange, A7A5 served as the primary vehicle for migrating high-value account holders to a successor platform, Grinex. Former Garantex customers received A7A5 credits matching their frozen balances, effectively moving assets off a seized exchange under the cover of a new token .

Connections to Iran, North Korea, and Hamas

TRM's "A7 Leaks" investigation found that the A7 network's crypto addresses had $176.6 million in exposure to the IRGC, Hamas, the Houthis, and Iranian-linked entities. One A7 address received over $65 million directly from the IRGC, and another received $5 million from Hamas. At least $590,000 in proceeds from North Korean government hacks of BTCTurk and Woo X also flowed through A7 addresses toward cash conversion .

Designed to resist freezing

Unlike USDT, A7A5 is not at risk of being frozen by Western authorities. Its structure allows Russian businesses to hold balances in A7A5 and swap for USDT later, creating a sanctions-resistant bridge between the ruble and global crypto markets .

Sanctions activity surged 400%

TRM Labs reported that sanctions-related crypto activity in 2025 was overwhelmingly driven by Russia-linked flows, largely due to A7A5, which drove a ~400% surge in sanction-dodging crypto activity year-over-year . Illicit entities received $141 billion in stablecoins in 2025, with $72 billion linked to A7A5 alone .

The Bottom Line

The dispute over A7A5's volume is not just a data methodology quarrel. It reflects a deeper contest over whether a state-backed stablecoin can sustain plausible real-world usage for sanctions evasion, or whether its billions in on-chain activity are largely an artifact of circular book-settling among a small, already-sanctioned network. The evidence from both TRM and Elliptic strongly points to the latter.