Persons who fall into any sanctions lists of the United States, Britain, the European Union and the UN Security Council will not be able to participate in any of the rounds of the closed ICO (initial coin offering - the initial placement of coins of crypto currency or tokens that give their owners certain rights) of the Telegram Open project Network (TON) by Pavel Durov. This is stated in the standard form of the contract for the purchase of Gram between the registered in the British Virgin Islands Telegram Group Inc. and the investor. A copy of the document is from RBC, its authenticity was confirmed by one of the Russian entrepreneurs, as well as the top manager of one of the venture funds that are considering the possibility of participating in the ICO project.
The ban also applies to the next of kin of such persons - children, spouses, parents, siblings. In addition, it is prohibited to participate in ICO to any citizen who is resident or residing in the territory in respect of which sanctions are common. The treaty states that at the time of writing they are considered to be the Crimea, Cuba, Iran, North Korea and Syria.
The document notes that all potential TON investors must undergo the procedure KYC (know your customer), adopted in the financial markets to identify clients and protect them from criminal activities. Within KYC, an individual is provided with such documents as a notarized copy of the passport, proof of residence, a recommendation from the bank.
Pavel Durov did not respond to RBC's request.
In the standard agreement between Telegram Group Inc. and the investor has separately noted that the buyer of the tokens has no right to use them for violation of the sanctions regime or money laundering, as well as terrorist financing. This is mentioned in the annex to the contract, which describes the risks of investing, selling and using Gram tokens. "Any illegal use of the Gram crypto currency by unscrupulous participants may violate the normative acts adopted in the UK, the US and other countries aimed at combating the financing of terrorism and money laundering. This can seriously affect the global reputation of TON Blockchain, "the document says.
However, the documents do not say whether TON itself will track suspicious transactions.
The problem of using crypto currency to finance illegal transactions is really quite acute. As previously reported by RBC, in late 2017 in RuNet appearedservice for the exchange of bitcoins for rubles and dollars, the site of which expressly states that it is used to "cash out unaccounted funds." Its creator is the company - a partner of the bank Interkommerts, from which the Central Bank has withdrawn a license because of "conducting doubtful transit operations." Earlier, the founder of the Chronopay payment system, Pavel Vrublevsky, told RBC that a significant increase in the bitcoin rate over the past year and a general "fever" around the crypto-currencies attracted a large number of scams to the industry. "The legalization of illegally obtained funds through their transfer to bitcoins is one of the most common schemes. The market, of course, is suffering from this, "he noted.
At the same time, the TON ecosystem described in the presentation for investors allows quite free to buy and sell Gram coins. The document says that by the end of 2017 in the Telegram messenger there were more than 800 thousand bots that used 52 million users. In the future, the company plans, all these bots will be able to accept payments in the Gram crypto currency. In addition, Telegram intends to launch an advertising exchange where users or companies can centrally purchase advertising in the Telegram channels they are interested in, paying for it in the Gram. In addition, channels and groups in Telegram will be able to receive donations from users to Gram or set up a system in which part of the content will be available only after payment (paywall).
Who will not be given a Gram
During the period 2014-2017, sanctions were imposed on events in Ukraine by a number of countries, including the USA, the EU, Canada, Australia, Switzerland, Japan, New Zealand and others. Basically, the residents of the Crimea, Russian and Ukrainian citizens (representatives of the unrecognized Donetsk and Lugansk People's Republics and persons from the environment of former Ukrainian President Viktor Yanukovich) were under sanctions.
The first sanctions against Russia were introduced by the US in March 2014. Sanctions against individuals have imposed a ban on their entry into the United States, as well as blocked bank accounts and property. The initial list included 11 people, including presidential aide Vladislav Surkov, presidential adviser Sergei Glazyev, Federation Council Chairman Valentina Matvienko, Deputy Prime Minister Dmitry Rogozin and others. Later, the sanctions list was expanded several times, the last time - in January 2018. At the moment, under American sanctions in connection with the events in Ukraine there are 181 people.
The European Union imposed sanctions in connection with the events in Ukraine on March 17, 2014, when 21 Russian and Crimean politicians and officials got under them. During the year, the EU expanded the sanctions list several times to 151 people. Then the EU extended the sanctions every six months, excluding dead people from it. In November 2016, the sanctions list was extended to six people, in November 2017, the governor of Sevastopol, Dmitry Ovsyannikov, was included. On March 12, 2018, the European Union extended sanctions against 150 individuals for six months.
To the EU sanctions, other European states that are not part of the EU have consistently joined: Norway, Iceland, Moldova, Switzerland and others. The UK joined the EU sanctions. The UN Security Council imposed sanctions against several Russian citizens, members of terrorist groups.