After the Toncoin → Gram rebrand and MTONGA step 3 (Telegram became the network’s largest validator), the sanctions profile of the network has objectively shifted. On one hand, Gram is legally the same asset Toncoin was (only the name changed). On the other, the corporate sponsor (Telegram) gives regulators a clear “point of pressure” that the community-run TON didn’t have.
This piece is a detailed analysis of what changes for compliance and what doesn’t. No alarmism, but an honest assessment of real risks.
!Disclaimer
Analytical content, not individual legal advice. The sanctions landscape moves fast. For significant positions and EU/US operations, consult a specialized lawyer.
OFAC US: current status and risks
Where we are now
OFAC (Office of Foreign Assets Control, US Treasury) maintains the Specially Designated Nationals (SDN) list — sanctioned entities and addresses. As of June 1, 2026:
- TON Foundation — NOT sanctioned
- Telegram FZ-LLC (UAE entity) — NOT sanctioned
- Gram / Toncoin as an asset — NOT sanctioned
- Specific TON addresses — some on the SDN list (Lazarus Group addresses, drug-trade entities)
- Pavel Durov personally — NOT sanctioned
What happened after Durov’s arrest
August 2024: Durov was arrested in France. The episode didn’t trigger an OFAC action against Telegram but increased scrutiny:
- US Treasury issued an advisory in October 2024 about risks of using messengers without KYC for crypto transactions
- No specific sanctions against Telegram or TON
Could OFAC sanction Gram?
Technically — three action tiers:
- Specific addresses (current practice) — add to SDN. Already happens for bad actors on any blockchain.
- Specific services (precedent: Tornado Cash, August 2022) — sanction a smart contract or service. Contested even in US law (federal court partially overturned Tornado Cash sanctions).
- Entire network or native asset — no precedent. Legally awkward — it’s not a “person” but a protocol.
For Gram, tier 3 is highly unlikely. Even in a worst-case US/Telegram fallout, the network itself keeps running, and OFAC enforcement stops at the address level.
What it means for a retail holder
If you’re a US resident holding Gram:
- Holding Gram per se is not prohibited by OFAC
- Prohibited: transacting with SDN-listed addresses
- Prohibited: using Gram to pay sanctioned entities
- Tonkeeper, MyTonWallet — self-custody, not CASP, not applicable to MiCA/CASP rules
EU MiCA: what changes after the rebrand
MiCA structure
EU Regulation 2023/1114 (Markets in Crypto-Assets) regulates crypto in the EU since full force in 2024. Three asset categories:
- E-money tokens — pegged to a single fiat (e.g. USDC, USDT)
- Asset-referenced tokens — pegged to a basket (DAI, for example)
- Other crypto-assets — everything else (BTC, ETH, TON, Gram)
Gram falls under Other crypto-assets, same as Toncoin before. No classification change after the rebrand.
What MiCA requires of CASPs
Crypto-Asset Service Providers (CASP) — exchanges, custodial wallets, brokers, advisors — must:
- Obtain a CASP license in one of the EU jurisdictions
- Apply KYC/AML to clients
- Comply with Travel Rule for ≥$1000 transfers
- Protect client funds via segregation
- Report to the regulator regularly
Wallet by Telegram is already registered as a CASP in the EU (since March 2025). After the rebrand — no legal-status change.
Self-custody wallets (Tonkeeper, MyTonWallet) — NOT CASPs, not under MiCA.
EU resident holding Gram — what changes
Nothing changes drastically:
- Holding Gram in self-custody — allowed
- Using DEXes (STON.fi, DeDust) — allowed (DEXes aren’t CASPs by default)
- Moving Gram via CEX (Bybit, OKX, MEXC) — allowed, but subject to those exchanges’ MiCA compliance (KYC + Travel Rule)
- Receiving Gram as gift / mining reward — allowed (but possibly a taxable event)
Travel Rule (FATF): for transfers ≥$1000
FATF Recommendation 16 (Travel Rule) requires VASPs (Virtual Asset Service Providers) to share identifying info on transfers ≥$1000 (€1000 in the EU). The EU implemented this via Transfer of Funds Regulation (TFR), in force since December 2024.
For Gram holders:
- Self-custody transfers: not in scope
- CEX → CEX: the exchange will pass your-name + recipient-name through a Travel Rule rail (Sumsub Travel Rule, Notabene, etc.)
- CEX → self-custody: the exchange will ask “whose wallet is this?” on large withdrawals
After the rebrand — no changes to TFR application.
Russian residents: specifics
Russia is not under direct US crypto sanctions (unlike Iran/Syria/North Korea). But secondary effects exist:
What a Russian resident can do
- Hold Gram in self-custody — allowed
- Trade on crypto exchanges (Bybit, OKX, MEXC) — allowed, but KYC limited for Russian passports
- P2P fiat-conversion — allowed via crypto bots (Crypto Bot, xRocket)
- Declare in 3-NDFL — see our Russian tax guide
What a Russian resident CANNOT do (legally)
- Use Gram to pay for goods/services inside Russia (2025 “Digital Currency Law”: prohibits use as means of payment)
- Receive salary directly in Gram (must be structured via individual entrepreneur)
- Issue your own jetton without a CB license
Geopolitical risk
With Telegram’s validator presence, TON may sit in a more sensitive geopolitical spot:
- US/EU may start viewing Telegram as a “Russian messenger” (despite UAE incorporation)
- Secondary sanctions possible if Telegram gets entangled in sanctions situations
- Not a certainty, but a risk factor for long-term planning
What Telegram does for compliance
After Durov’s arrest, Telegram materially strengthened compliance:
- Wallet by Telegram CASP registration in the EU (March 2025)
- Expanded cooperation with EU law enforcement (Europol)
- Improved moderation of crypto scams in channels
- OFAC screening for large transactions through Wallet
At the Gram network level (smart-contract level) — no filtering. Self-custody users don’t depend on Telegram compliance.
What Telegram’s validator can (and cannot) do
A primary concern after MTONGA step 3 is that the Telegram validator can censor transactions. The realistic picture:
What Telegram’s validator cannot do
- Freeze your balance
- Change Gram’s supply
- Reverse a transaction after the fact
What it could do (theoretically)
- Not include specific transactions in its own block (other validators still include them — a 1–2 sec delay)
- Coordinate with other large validators (requires social capital, unlikely)
- Block Telegram app-level access (banned wallets may lose Wallet access)
More in our centralization analysis.
Action items for Gram holders under sanctions context
Checklist by jurisdiction:
If you’re in the US
- Don’t transact with SDN-listed addresses (check via Tonviewer before large transfers)
- Use US-regulated CEXes (Coinbase, Kraken) for fiat cash-out on large sizes
- Declare Gram on IRS Form 8949 on sales
- Self-custody via Tonkeeper / MyTonWallet — not a CASP, not applicable
If you’re in the EU
- Use CASP-licensed exchanges (most majors already licensed)
- Travel Rule > €1000: expect KYC prompts
- File with your local tax office (Germany, France, Italy — different rules)
- MiCA doesn’t require action from self-custody users
If you’re in Russia
- Self-custody — unrestricted
- Tax: 13%/15% on profit (see our tax guide)
- DO NOT use Gram as a means of payment inside Russia
- P2P via crypto bots — allowed
If you’re in Eastern Europe / Belarus / CIS
- Most countries — permissive regime (Georgia, Armenia, Belarus, Kazakhstan)
- Tax varies by country (typically 0–15%)
- Check local regulations separately
Long-term outlook
12 months out (June 2027)
Base case: no major sanctions against Gram. Standard CEX compliance continues; self-custody is free.
Pessimistic case: secondary OFAC action in case of US-Telegram fallout. Impact: some US-licensed exchanges delist Gram. But this doesn’t affect globally.
Optimistic case: clarity regulation in the US via FIT 21 / CLARITY Act explicitly designates Gram a commodity (not security). That lowers regulatory risk and brings institutional capital.
Sources
- OFAC SDN List, June 2026
- EU Regulation 2023/1114 (MiCA)
- EU Regulation 2023/1113 (TFR / Travel Rule)
- FATF Recommendation 16 (Travel Rule)
- US Treasury advisories (2024–2026)
- Tether Operations OFAC compliance reports
Further reading:
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