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 take part in any round of the Telegram ICO. As reported by RBK, 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.
The ban also applies to the next of kin of such persons - children, spouses, parents, siblings. In addition, the ICO is prohibited from participating in any citizen who is resident or residing in the territory in respect of which sanctions are common - at the time of writing the agreement they are considered to be Crimea, Cuba, Iran, North Korea and Syria.
The document notes that all potential TON investors must undergo the KYC procedure 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, etc.
Separately in the standard agreement between Telegram Group Inc. and the investor states that the buyer of the tokens is not entitled to use them to violate the sanctions regime or money laundering, as well as terrorist financing.
Any illegal use of the Gram cryptocurrency 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.
TON ICO Document
However, the documents don't say whether TON itself will track suspicious transactions.