Case study · website unblocking

Case on unblocking a cryptocurrency exchange service

A crypto exchange serving Russian users found its domain added to the restricted-information registry by order of the Prosecutor General's Office. We audited the content, resolved the violations, and coordinated with three regulators - access was restored.

Blocking basis

Article 15.3, Law 149-FZ

Regulators

Prosecutor General · RKN · CBR

Industry

Crypto exchange services

Situation

A crypto exchange serving users in Russia discovered its domain had been listed in the registry of information distributed in violation of the law. Access was restricted by order of the Prosecutor General's Office under Article 15.3 of Federal Law No. 149-FZ.

The regulator classified the posted content as inaccurate and posing a threat to financial institutions. This created three interlinked risks: complete loss of Russian traffic, potential scrutiny from the Central Bank of Russia, and the prospect of a prolonged block with no clear resolution path.

What we did

We structured the engagement in sequential stages - from diagnosing the grounds for the block to confirming the lifting of restrictions.

  • Conducted a full site audit to identify the content that triggered regulatory action
  • Provided specific remediation recommendations and coordinated edits with the client
  • Removed the information that formed the formal basis for the block
  • Prepared and submitted reasoned appeals to:
    • Roskomnadzor
    • the Prosecutor General's Office
    • the Central Bank of Russia
  • Managed communication with each regulator and monitored proceedings through to the final decision

Result

The Central Bank of Russia conducted an additional review and initiated the removal of restrictions. Access to the site was restored for users in Russia.

The service avoided prolonged blocking, loss of the Russian market, and further regulatory sanctions. Specific timelines and correspondence are not disclosed per our obligations to the client.

Business outcome

The service returned to normal operation for the Russian audience. The legal grounds for the restrictions were eliminated, and the risk of repeat action from three regulators was reduced. The team received a clear response protocol for similar situations going forward.

Facing a block or at risk of one?

Tell us about the situation - we will assess the grounds and propose a concrete action plan.