Ukraine Presidential Decree 465/2025 — Bitfury Group and Vavilov Sanctioned Among 60 Crypto Entities

What Happened

President Volodymyr Zelenskyy signed Presidential Decree No. 465/2025 on July 6, 2025, enacting an NSDC decision imposing personal special economic measures (sanctions) on 60 legal entities and 73 individuals for alleged participation in Russia’s evasion of international financial sanctions and financing of Russia’s military-industrial complex.

Decree number confirmed: 465/2025
Date confirmed: July 6, 2025
Source: zakon.rada.gov.ua — Ukraine’s official legal database (Tier-1 primary)
Decree title: “On the Decision of the National Security and Defense Council of Ukraine from July 6, 2025 — On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)”

Scope of the Sanctions Package

The 60 sanctioned legal entities were categorized by the Ukrainian Commissioner for Sanctions Policy as:

• 19 cryptocurrency miners
• 17 digital financial asset information system operators (already under US sanctions)
• 5 crypto exchange operators
• 19 firms in Russia’s financial infrastructure (payment equipment, asset exchanges, international payment intermediaries)

Five non-Russian entities were included: Token Trust Holdings Limited (Cyprus), EXMO RBC Limited (Kazakhstan), AWX Solutions (UAE), Crypto Explorer DMCC (UAE), and Bitpapa IC FZC (UAE).

Bitfury Group and Vavilov — Status: Research-Not-Confirmed

The specific naming of Bitfury Group and Valery Vavilov within Decree 465/2025 is confirmed only at Tier-2/3, not Tier-1.

• Decree 465/2025 is confirmed at Tier-1 (zakon.rada.gov.ua); its full annex listing all sanctioned entities is attached but not machine-readable from the primary source page.
• Mayer Brown’s July 2025 sanctions tracker (Tier-1 law firm specialist) confirmed Decree 465/2025 but did NOT specifically name Bitfury or Vavilov.
• Cryptopolitan (Tier-2) and Mitrade (Tier-2) reported Bitfury and Vavilov as sanctioned under this decree.
• Trinity Bugle and Assay News (both Tier-3) named Bitfury/Vavilov and attributed the $3 billion figure — both sites were unreachable during this research session (HTTP 520).
• OpenSanctions NSDC database as of June 7, 2026 shows NO entry for Bitfury Group or Vavilov — discrepancy unresolved (see below).

Status designation: research-not-confirmed — Bitfury/Vavilov inclusion in Decree 465/2025 is plausible and multiply-reported at Tier-2, but cannot be confirmed via Tier-1 primary source text (full annex not retrieved) or the official NSDC register.

The $3 Billion Figure

Zelenskyy’s own public statement cited “several billion dollars through one single company” — without naming that company. The specific “$3 billion” figure and the attribution of that figure to Bitfury/Vavilov originates from Tier-2/3 outlets reporting Ukrainian government allegations. It is not directly sourced to decree text or an official NSDC press release citing Bitfury by name.

Editorial framing required: The $3 billion figure must be attributed as “Ukrainian government allegations reported by [outlet]” — not stated as established fact.

NSDC Register Discrepancy — Unresolved

The Ukraine NSDC State Register of Sanctions (drs.nsdc.gov.ua), as reflected in OpenSanctions (updated hourly, last change June 7, 2026), shows no Bitfury Group or Vavilov entry. Possible explanations:

1. Data lag or indexing gap: The register is updated synchronously with presidential decrees, but the OpenSanctions crawler may have a parsing or data-feed gap for the July 2025 package.
2. Different mechanism: Decree 465/2025 may operate through a presidential sanctions channel that is indexed separately from the NSDC register OpenSanctions crawls.
3. Inaccurate media reporting: The Tier-3 sources may have incorrectly identified Bitfury as a named entity in the decree. This scenario is possible but less likely given Tier-2 confirmation.

This discrepancy requires interactive access to drs.nsdc.gov.ua to resolve definitively.

Connection to Jonathan Gould / OCC

Jonathan Gould served as Bitfury Chief Legal Officer from February 9 – September 2022, confirmed at Tier-1 (Business Wire). He was confirmed as the 32nd Comptroller of the Currency on July 15, 2025 — nine days after this decree was signed.

The structural significance: A future top US bank regulator’s former employer was sanctioned by Ukraine (for alleged Russia-linked conduct) the same week he was confirmed to regulate US banks. The revolving-door pattern (Gould + CEO Brian Brooks, both former senior OCC officials, simultaneously leading Bitfury in 2022) means the double-OCC-revolving-door firm is now a sanctioned entity. The Senate confirmation process did not address the Russia/Ukraine/sanctions dimension of Gould’s Bitfury tenure.

Research Gaps

• Full annex text of Decree 465/2025 confirming Bitfury Group listed by name (requires direct access to zakon.rada.gov.ua full document download or drs.nsdc.gov.ua search)
• Explanation for NSDC register discrepancy (requires interactive database access)
• UK/EU designation status — media referenced possible UK follow-on sanctions; not confirmed
• Source of $3 billion figure independent of Tier-3 outlets