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And why Bitcoin remains the only way out

With a market capitalization of about $186 billion, USDT has become the digital dollar for millions of people. However, the token's issuer can freeze funds at a specific address at any time — and regularly exercises this right. In just the last six months, Tether has added 2,362 addresses to its blacklist on the Ethereum and TRON networks, blocking $1.64 billion on them. Such decisions usually target hackers and scammers, but the very possibility of freezing means that even on a non-custodial wallet, the holder does not fully control the tokens.

Together with the team behind the Bitcoin mixer Mixer.Money, we explore how the USDT freeze mechanism works, why ordinary users sometimes get caught up in it, and why holding funds in stablecoins is riskier than holding Bitcoin.

The Ardoino List: How the Freeze Mechanism Works

USDT is a centralized stablecoin, and Tether does not hide this fact. The company's CEO, Paolo Ardoino, emphasizes this feature of the token and often contrasts it with Bitcoin as an alternative. The ability to block an address and forcibly destroy tokens is embedded in Tether's smart contracts on Ethereum (ERC-20), TRON (TRC-20), Solana, and other networks. The function names may differ, but the principle is the same:

• Adding to the blacklist (addBlackList) — the address owner loses the ability to send USDT; any transfer is rejected at the contract level. The address itself remains active: it can receive new USDT and freely use the network's native coin like ETH, TRX, or SOL;
• Removal from the blacklist (removeBlackList) — restores the ability to transfer tokens;
• Destruction of funds (destroyBlackFunds) — irreversibly burns USDT at the blocked address. The owner can no longer recover them.

After burning, Tether can issue an equivalent amount of tokens at another address. Re-issuance is used when funds are returned to victims or transferred to wallets under law enforcement control. "In other words, the issuer can take dollars from one address and re-issue them in favor of another," notes Mixer.Money.

According to BlockSec, it takes an average of about two days between issuing a freeze order and its execution on the network. The status of an address on the Ethereum and TRON networks can be checked using the company's checker.

Promissory Note vs. Digital Gold

Behind every freeze is an external request. According to BlockSec, Tether freezes an address based on a single verified request from law enforcement — without warning the holder or providing an appeal process before the freeze. The user learns about the restriction only after the freeze has occurred. The T3 Financial Crime Unit (T3 FCU) — a joint project of Tether, TRON, and analytics firm TRM Labs — executes the freeze within 24 hours. Since its creation in September 2024, the alliance had frozen over $450 million across 23 jurisdictions by May 2026.

The stablecoins themselves are identified for freezing by on-chain analytics companies like Chainalysis, Elliptic, and TRM Labs. They assign risk levels to wallets and link them together. If an address receives a high risk score, AML systems also raise the score for wallets associated with it. Sometimes, random users whose coins once passed through a recognized "dirty" address end up under restrictions. Analysts also track Bitcoin, but it is impossible to take it from its owner without the private keys.

USDT and USDC are debt obligations of a centralized issuer. The issuer retains control at the contract level: blocking transfers, burning balances, and re-issuing amounts. The holder controls the private keys but not the token's rules. Bitcoin has no administrator, no blacklist functions, and no "big red button" like destroyBlackFunds. There is simply no one to execute such a request. This does not eliminate the risk of freezing entirely — it shifts from the protocol level to the level of exchanges, swap services, and other centralized platforms where users must verify documents and may have their accounts frozen.

Attempts to impose censorship within the Bitcoin network itself have already been made. In 2021, mining company MARA launched the first OFAC-compliant pool in North America, which filtered transactions against sanctions lists. The community saw this as a threat of censorship at the block production level and sharply criticized the initiative. Two months after the announcement, MARA shut down the experiment.

Converting USDT to Bitcoin removes the risk of freezing at the issuer level. However, it does not eliminate on-chain surveillance: contrary to popular belief, the first cryptocurrency is not anonymous but pseudonymous.

Privacy After Conversion

To hide the link between addresses, additional tools are required. There are several ways to break the on-chain trail, each with its own limitations:

• CoinJoin — the joint mixing of coins from multiple users in a single transaction. This mechanism is usually recognized by analytics systems, so the mere use of CoinJoin can increase an address's risk score;
• Centralized mixers — they do not combine users in a single transaction but instead accept funds into their own pool and then send other coins. This breaks the direct on-chain link between input and output but requires trust in the service operator;
• Bitcoin mixers using verified coins — they do not mix user funds with each other and do not use their own liquidity pool. Instead, they utilize verified clean coins from trusted investors, allowing them to break the direct on-chain link between incoming and outgoing transactions.

Mixer.Money falls into the last category. Unlike CoinJoin, it does not mix funds from different participants. The bitcoin.mixer 2.0 algorithm uses verified clean bitcoins from trusted investors, which breaks the direct link between incoming and outgoing transactions. In "Full Anonymity" mode, coins are split into random parts in a premixer and sent to independent investors. After a random interval, which protects against timestamp analysis, the sender receives an equivalent amount minus a fee. The funds arrive at two new addresses not on-chain linked to the original wallet. "CoinJoin is easily identified on-chain and itself increases the risk score. Many exchanges and swap services warn about account blocking for using such services," emphasizes Mixer.Money.

Panopticon Tether: The Downside of Control

The freeze function helps investigate crimes and return funds to scam victims. During its operation, T3 FCU has been involved in cases related to money laundering, drug trafficking, terrorist financing, and the activities of North Korean hacker groups. The FATF has called the unit an "invaluable resource for law enforcement agencies worldwide." Such activities contribute to growing regulatory trust in the crypto industry as a whole.

However, this system also has a downside. USDT remains a centralized asset, and access to funds ultimately depends on the issuer's decisions and requests from authorities. In essence, the stablecoin has become a node in a global surveillance system: a private company, connected to hundreds of agencies and analytics services, can freeze "digital dollars" almost anywhere in the world. In this sense, the USDT ecosystem resembles a digital panopticon: most users never directly encounter restrictions but know that such a possibility exists. The effectiveness of this mechanism strengthens regulatory trust but simultaneously continues to blur the boundaries of financial autonomy, which are already narrowing as cash is gradually phased out. "Diversification" among major stablecoins only spreads the dependence across different companies, but the freeze architecture remains.

Bitcoin has no administrator or single control center, so there is simply no one to execute a request to freeze funds at the protocol level. This makes it the only major digital asset that does not depend on decisions made by an issuer, regulator, or bank. The first cryptocurrency cannot be frozen, seized, or burned by a third party's decision, and its issuance rules remain unchanged regardless of state inflation policies or legislative changes.

Bitcoin protects against arbitrary freezing of funds but does not hide financial activity from prying eyes. All transactions are recorded in a public ledger and can be analyzed years after they are made. Privacy-enhancing solutions like Mixer.Money help reduce the digital footprint.

Expert Commentary: Ultimately, the choice between USDT and Bitcoin is not just a matter of convenience or liquidity. It is a fundamental choice between trust in a centralized issuer and complete financial sovereignty. USDT has become an indispensable tool for the market, but its architecture makes every holder vulnerable to decisions made behind closed doors. Bitcoin, on the other hand, remains the only digital asset where control over funds truly belongs solely to the owner of the private keys.