MOSCOW (Realist English). The digital asset market and peer‑to‑peer cryptocurrency trading are growing — and with them, specific forms of unlawful behaviour are multiplying. One such form, known as the “black triangle,” has become a genuine legal nightmare for bona fide market participants.
The victims of this scheme are ordinary citizens who have no intent to commit unlawful acts, yet face serious legal consequences — from bank account freezes to criminal prosecution.
Attorney Narek Petrosyan, who specialises in protecting the rights of cryptocurrency market participants, examines the legal nature of this scheme, the associated risks, and possible defence mechanisms for those inadvertently caught up in such operations.
What Is the “Black Triangle” and How Does It Work?
The “black triangle” is one of the most common fraud schemes in cryptocurrency purchase and sale transactions conducted via P2P platforms (Binance, Bybit, Garantex, and others) and illegal exchangers. Its key feature is the involvement of three parties — two of whom are victims, and the third being the direct beneficiary (the fraudster).
| Participant | Role in the Scheme |
| Victim No. 1 (crypto seller) | A bona fide seller who receives money from Victim No. 2 and transfers cryptocurrency to the fraudster |
| Victim No. 2 (buyer of crypto or goods) | Transfers money to the seller’s account, believing they are paying for crypto or goods |
| Fraudster | Receives cryptocurrency from the seller and disappears |
Two main variations of the scheme:
First, the classic version — all three participants interact within a P2P platform. The fraudster opens a deal to buy cryptocurrency from a seller (Victim No. 1), obtaining their payment details. Simultaneously, he initiates a deal to sell cryptocurrency to a buyer (Victim No. 2) for the same amount. The buyer transfers money to the seller’s account, believing they are paying for the crypto they are purchasing. The seller, having received the money and believing the counterparty to be honest, transfers the cryptocurrency to the fraudster’s address, who then deletes all correspondence and disappears.
Second, the more complex version — the fraudster uses third‑party platforms unrelated to the crypto market (e.g., Avito or other classified‑ad services). Under the pretext of selling some goods (often at a deliberately low price), he persuades a buyer to transfer money to the crypto seller’s payment details – the seller being a participant in a P2P deal on the exchange. The seller, receiving payment, transfers cryptocurrency to the fraudster. Ultimately, the goods buyer is left with neither goods nor money, and the crypto seller is threatened with criminal prosecution.
Legal Risks: From Witness to Accused
The crypto seller, into whose bank account the victim’s funds were transferred, is treated by law enforcement as the “end” link in the criminal chain. At the initial stage of investigation, such a seller may be questioned as a witness. However, in the absence of sufficient evidence of their good faith, their procedural status may be changed to suspect or accused.
| Article of the Criminal Code of the Russian Federation | Charge |
| Art. 159 | Fraud |
| Art. 174 or 174.1 | Legalisation (laundering) of funds |
The decisive factor in qualification is establishing whether the person knew or should have known about the criminal origin of the funds received into their account.
Account Freezes Under Federal Law No. 161‑FZ: Over 200,000 Records in the “Black Database”
The most common consequence of being caught in the “black triangle” scheme is the freezing of bank accounts under Federal Law “On the National Payment System” of June 27, 2011 No. 161‑FZ. Under Article 9, Part 11.6, a bank has the right to suspend a client’s use of an electronic payment instrument if information about that client or their payment details is contained in the Bank of Russia’s database of cases and attempts to carry out money transfers without the client’s voluntary consent.
According to statements by Deputy Chairman of the Bank of Russia German Zubarev, the database currently contains more than 200,000 unique payment details. Information is provided both by credit institutions and by the Ministry of Internal Affairs of the Russian Federation. Approximately half of the information collected under this database is linked to participants in the “triangle” scheme.
Civil Law Risks: Claims for Unjust Enrichment
In addition to criminal and administrative risks, a person whose account received stolen funds may face civil‑law consequences. Victims often justify their claims by the absence of any contractual relationship with the recipient of the funds and, accordingly, no legal grounds for retaining them.
In such cases, the received funds are classified as unjust enrichment (Article 1102 of the Civil Code of the Russian Federation), subject to full restitution, including interest for the use of another’s funds (Article 395 of the Civil Code).
At the same time, as attorney Narek Petrosyan notes, in the absence of objective data confirming the wrongfulness of the defendant’s actions in cryptocurrency sale transactions, and without proof of a causal link between the defendant’s actions and the resulting fraud, the court may dismiss the claim. If the plaintiff fails to provide proper evidence, while the defendant confirms the bona fides of their intentions, there may be no legal grounds for imposing an obligation to return the money.
Legislative Initiatives: Rehabilitation for Bona Fide Sellers
The Bank of Russia, acknowledging the problem, has proposed a number of relaxations for persons inadvertently caught up in the “triangle” scheme.
| Initiative | Essence |
| Time limit in the “black database” | Since February 2026, the regulator has proposed limiting the period of inclusion in the fraud‑related database to one year, instead of the effectively indefinite retention |
| Rehabilitation mechanism | If a crypto seller had no intent to assist criminals and is willing to return the stolen money to the rightful owner, their details may be removed from the Central Bank’s “black database” |
However, according to experts, parallel discussions are underway on tightening cryptocurrency market regulation and increasing liability for transactions conducted outside the legal segment.
Attorney’s Recommendations: How to Minimise Risks
For individuals conducting cryptocurrency purchase and sale operations on P2P platforms, attorney Narek Petrosyan offers the following practical recommendations:
- Counterparty identification. Carefully check the counterparty’s details: compare the name in the profile with the name of the bank account holder. Any discrepancy should be treated as a sign of possible third‑party involvement (the fraudster).
- Refusal of non‑standard payment terms. The most common red flag is a counterparty’s proposal to make a transfer from a third party under various pretexts (helping a friend, alternative payment method, technical error). Such proposals must be firmly declined.
- Demand proof of transfer. Request confirmation of the transfer from the counterparty, including the transaction number on the platform. The absence of such a number or a refusal to provide it should be treated as a risk‑increasing circumstance.
- Preservation of evidence. Keep all screenshots of orders, correspondence with the counterparty on the platform, and the transaction identifier (TXID). Such materials can serve as proof of the participant’s good faith.
- Immediate legal assistance. At the first signs of involvement in the “black triangle” scheme (notification of account freeze, summons to law enforcement), immediately seek qualified legal help, as both the outcome of any investigation and the prospects of criminal prosecution depend on the timeliness and correctness of the chosen defence strategy.
Legal Uncertainty as the Main Risk
The “black triangle” scheme poses a serious challenge to law enforcement in the digital asset sphere. Its distinctive feature is that fraud victims include not only the direct losers of funds, but also bona fide P2P traders who unwittingly become entangled in the laundering of stolen funds.
The lack of specific legislative regulation of the cryptocurrency market exacerbates legal uncertainty and increases risks for all participants in such operations. In these circumstances, it is crucial not only to improve legislation but also to raise the legal literacy of citizens conducting crypto transactions, as well as their awareness of existing risks and available defence mechanisms.
Attorney Narek Petrosyan
