Is Crypto Legal in Iran?
Overview
Iran operates without a dedicated VASP or crypto-asset framework — no anchor legislation for exchanges or custody has been recorded — but regulates cryptocurrency through existing financial and industrial rules: licensed mining is the sole clearly authorized activity, requiring a permit from the Ministry of Industry, Mine and Trade, while the Central Bank of Iran has explicitly banned cryptocurrency for domestic payments and imposes existing AML/KYC and transaction-monitoring obligations on any entity authorized to handle virtual assets. The CBI serves as the primary financial regulator, with Tavanir and the Law Enforcement Force actively raiding and prosecuting unlicensed mining operations. The single most decision-relevant fact is that Iran is subject to extensive international sanctions, primarily from the United States, which prohibit most financial transactions involving Iranian entities or individuals, effectively foreclosing compliant cross-border VASP operations regardless of domestic licensing status. (intam.gov.ir, mimt.gov.ir)
Regulatory Bodies
Iran has not established a specific licensing framework for cryptocurrency and digital asset businesses as of 2025–2026; instead, digital asset activities are governed indirectly through general sanctions, trade, and financial regulations…
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies.
The primary regulatory bodies are the U.S.
FIU: The primary FIU in Iran is located within the Secretariat of the High Council for Combating Money Laundering and Financing of Terrorism, which is part of the Ministry of Economy and Financial Affairs.
Ministry of Industry, Mines, and Trade (MIMT): Responsible for licensing and regulating cryptocurrency mining operations.
National Cyberspace Center (NCC) / Economic Council / Parliament: These bodies are involved in drafting and approving broader legislation concerning digital assets and cyberspace, which may eventually include more detailed provisions for…
Operating Models
9/9 verdictsCan specific business models operate in Iran? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
Conditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · no licensing.
AI · UnreviewedNot permitted.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedPrimary Legislation
| Law / Regulation | Year | Scope |
|---|---|---|
| The Electronic Commerce Law (unofficial) | The Electronic Commerce Law (unofficial) – general legal framework that may apply to digital transactions, though not crypto-specific. | |
| No comprehensive crypto-asset law exists | No comprehensive crypto-asset law exists: Iran lacks a dedicated legal framework for cryptocurrency exchanges, wallets, token issuances, and related digital asset services, creating significant legal uncertainty for businesses. |
Licensing Requirements
Iran has not established a specific licensing framework for cryptocurrency and digital asset businesses as of 2025–2026; instead, digital asset activities are governed indirectly through general sanctions, trade, and financial regulations administered by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) Federal Register :: Publication of Iran-Related Web General Licenses U and V
The primary regulatory bodies are the U.S. Department of the Treasury's OFAC, which administers the Iranian Transactions and Sanctions Regulations (ITSR) at 31 CFR Part 560, and the Department of Commerce's BIS, which administers export controls under Section 746.7 of the Export Administration Regulations (EAR) Federal Register :: Iranian Transactions and Sanctions Regulations
No entity has been granted a license to operate a cryptocurrency exchange or digital asset business in Iran under the U.S. regulatory framework; OFAC issues only temporary, transaction-specific general licenses (such as GL U, GL V, and GL X) for crude oil, petroleum products, and petrochemicals — not for digital assets Issuance of Iran-related General License | Office of Foreign Assets Control
The practical reality is that any crypto-related activity involving Iran is subject to a comprehensive U.S. sanctions regime that generally prohibits unauthorized transactions, with very narrow exceptions limited to humanitarian communications-related software and services Iran export controls | Bureau of Industry and Security
There is no Iranian domestic licensing authority for digital assets identified; the applicable legal framework is extraterritorial U.S. sanctions law, meaning a "license" from relevant U.S. agencies is required for lawful engagement Federal Register :: Iranian Transactions and Sanctions Regulations
The Office of Foreign Assets Control (OFAC) is the principal regulator for transactions involving Iran, operating under the Department of the Treasury and publishing licenses and regulations on its website at https://ofac.treasury.gov Federal Register :: Publication of Iran-Related Web General Licenses U and V
The Bureau of Industry and Security (BIS) of the Department of Commerce regulates exports to Iran under Section 746.7 of the Export Administration Regulations (EAR), requiring licenses for most items on the Commerce Control List (CCL) Iran export controls | Bureau of Industry and Security
The primary law is the Iranian Transactions and Sanctions Regulations (ITSR), codified at 31 CFR Part 560, which was reissued in its entirety on October 22, 2012 (77 FR 64664) and has been amended several times since, including a final rule effective May 17, 2024 (89 FR 43311) Federal Register :: Iranian Transactions and Sanctions Regulations
Additional relevant regulations include the Iranian Financial Sanctions Regulations (31 CFR Part 561), Iranian Sector and Human Rights Abuses Sanctions Regulations (31 CFR Part 562), Weapons of Mass Destruction Proliferators Sanctions Regulations (31 CFR Part 544), Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587), Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589), and Global Terrorism Sanctions Regulations (31 CFR Part 594) Federal Register :: Publication of Iran-Related Web General Licenses U and V
Executive orders governing Iran-related sanctions include E.O. 13876 of June 24, 2019 ("Imposing Sanctions With Respect to Iran"), E.O. 13902 of January 10, 2020 ("Imposing Sanctions With Respect to Additional Sectors of Iran"), and E.O. 13949 of September 21, 2020 ("Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of Iran") Federal Register :: Publication of Iran-Related Web General Licenses U and V
The United States is not a FATF member, and no information on Iran's FATF or Moneyval status is available in the current regulatory framework; the relevant international standing concern is that Iran is subject to comprehensive U.S. sanctions Iran export controls | Bureau of Industry and Security
OFAC has authority to issue general licenses (GLs) through the ITSR, including the authority to publish them on the Federal Register and on OFAC's website, as demonstrated by GL D, GL D-1, GL D-2, GL U, GL V, and GL X Federal Register :: Iranian Transactions and Sanctions Regulations
A license from BIS is required to export or reexport most items on the Commerce Control List (CCL) to Iran pursuant to Section 746.7 of the EAR; this includes technology and software that may be relevant to digital asset infrastructure Iran export controls | Bureau of Industry and Security
If OFAC authorizes the export or reexport of an item subject to the EAR, no separate BIS authorization is required for that same item, as the OFAC authorization is considered authorization for purposes of the EAR Iran export controls | Bureau of Industry and Security
A BIS license may still be required even with OFAC authorization for deemed exports (transfers of controlled technology and certain software to Iranian nationals in the U.S. or a third country), exports to persons on BIS's Entity List, and exports for prohibited end uses per Part 744 of the EAR Iran export controls | Bureau of Industry and Security
No license exceptions may be used for exports or reexports to Iran of items subject to the EAR, meaning the general licensing exceptions available for other destinations are not applicable Iran export controls | Bureau of Industry and Security
The licensing policy for Iran is that applications for humanitarian reasons and for the safety of civil aviation and safe operation of U.S.-origin aircraft will be considered on a case-by-case basis; licenses for other purposes generally will be denied Iran export controls | Bureau of Industry and Security
OFAC has issued specific general licenses for limited purposes: GL U (issued March 20, 2026) authorized the sale, delivery, or offloading of crude oil or petroleum products of Iranian origin loaded on vessels on or before March 20, 2026, through April 19, 2026; GL V (issued April 24, 2026) authorized the wind down of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd., through May 24, 2026; GL X (issued June 22, 2026) authorized the production, delivery, and sale of crude oil, petrochemical products, and petroleum products of Iranian origin through August 21, 2026 Federal Register :: Publication of Iran-Related Web General Licenses U and V
GL D-2, issued September 23, 2022, authorized the export and reexport of certain services, software, and hardware incident to communications over the internet, including cloud-based services, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services, but this does not extend to digital asset services Federal Register :: Iranian Transactions and Sanctions Regulations
The application process for OFAC licenses involves submitting an application to OFAC, which may require a BIS commodity classification to support the application for certain items; OFAC's Assistant Director for Licensing can be contacted at 202-622-2480 Federal Register :: Iranian Transactions and Sanctions Regulations
No capital requirements, monetary thresholds, or structural requirements (such as board composition or local presence) are specified for any type of license related to Iran; minimum capital for OFAC or BIS licenses is not established Iran export controls | Bureau of Industry and Security
Zero entities have been licensed to conduct cryptocurrency or digital asset business in Iran under any framework described; no such license has been announced or published by OFAC or BIS Issuance of Iran-related General License | Office of Foreign Assets Control
The timeline for license processing is not specified, though GL U (one month), GL V (one month), and GL X (approximately two months) are time-limited authorizations, indicating that general licenses are issued for defined, short durations Federal Register :: Publication of Iran-Related Web General Licenses U and V
No specific AML/KYC requirements, including customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership identification, or politically exposed person (PEP) screening requirements, have been published for cryptocurrency or digital asset businesses operating in Iran
OFAC's general licenses contain conditions, such as those in GL D-2 that restrict the exportation of web-hosting services and domain name registration services, which suggests that licensees must comply with specified conditions and limitations, but no explicit KYC/AML obligations are stated in the published text Federal Register :: Iranian Transactions and Sanctions Regulations
Prohibitions on exports to persons on BIS's Entity List and for prohibited end uses (Part 744 of the EAR) function as a form of counterparty screening obligation, requiring licensees to ensure they are not transacting with prohibited persons or for prohibited purposes Iran export controls | Bureau of Industry and Security
For any digital asset business dealing with Iran, standard OFAC compliance mechanisms would apply, though the absence of explicit KYC/AML rules in the regulations should be noted as a gap
No specific enforcement actions, penalties, fines, arrests, or cases related to cryptocurrency or digital asset activities involving Iran have been published
The regulations reference general sanctions enforcement authorities, including violations of the EAR for exporting items subject to the EAR without a required OFAC authorization, "even if the transaction would not have required a license from BIS," indicating that failure to obtain OFAC authorization is itself a violation Iran export controls | Bureau of Industry and Security
GL V was issued to authorize the wind down of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd., which implies that Hengli Petrochemical was designated or sanctioned under E.O. 13902, but no enforcement action against a digital asset entity is described Federal Register :: Publication of Iran-Related Web General Licenses U and V
The references to E.O. 13876 (June 24, 2019), E.O. 13902 (January 10, 2020), and E.O. 13949 (September 21, 2020) indicate that these authorities have been used to impose blocking sanctions on persons and sectors, but no specific enforcement cases involving crypto entities are listed Federal Register :: Publication of Iran-Related Web General Licenses U and V
The wind-down authorization in GL V, expiring May 24, 2026, suggests enforcement pressure had been applied to the relevant entity, but no fines, penalties, or arrest details are provided in the regulations Federal Register :: Publication of Iran-Related Web General Licenses U and V
The expiration of GL U on April 19, 2026, and the subsequent issuance of GL X on June 22, 2026, indicate that unauthorized transactions after license expiration would be subject to enforcement, but no specific enforcement action is described Issuance of Iran-related General License | Office of Foreign Assets Control
No tax guidance has been issued for virtual assets; none of the referenced documents from OFAC, BIS, or the Federal Register address the taxation of cryptocurrency or digital assets in Iran
The regulations are exclusively focused on sanctions, export controls, and licensing under U.S. law; there is no discussion of Iranian domestic tax law, including income tax, capital gains tax, or value-added tax (VAT) treatment of digital assets Federal Register :: Iranian Transactions and Sanctions Regulations
No Iranian tax authority, tax code, or tax regulation is referenced in any of the published regulatory documents Issuance of Iran-related General License | Office of Foreign Assets Control
The absence of any tax-related provisions in the general licenses (GL U, GL V, GL X) suggests that tax treatment of authorized transactions is not addressed within the sanctions licensing framework Federal Register :: Publication of Iran-Related Web General Licenses U and V
For U.S. persons involved in any authorized Iran-related transaction, U.S. federal tax obligations would apply by default, but no analysis or guidance on this point is available in the current framework Iran export controls | Bureau of Industry and Security
There is no comprehensive or specific regulatory framework for cryptocurrency and digital asset licensing in Iran; the only "licensing" available is under U.S. sanctions law for narrow, non-digital-asset purposes Federal Register :: Publication of Iran-Related Web General Licenses U and V
No entity has obtained a license to operate a cryptocurrency exchange, custody service, or other digital asset business involving Iran, and no pathway for obtaining such a license is evident Issuance of Iran-related General License | Office of Foreign Assets Control
The licensing policy states that licenses for purposes other than humanitarian reasons and civil aviation safety "generally will be denied," meaning a digital asset business license application would almost certainly be rejected Iran export controls | Bureau of Industry and Security
The absence of AML/KYC requirements creates significant legal uncertainty for any business attempting to engage with Iran's digital asset space, as there is no formal compliance framework to follow Federal Register :: Iranian Transactions and Sanctions Regulations
The overlapping jurisdictions of OFAC (ITSR at 31 CFR Part 560) and BIS (EAR Section 746.7) create compliance complexity, as a business may need authorizations from both agencies, with separate requirements for deemed exports, Entity List screening, and end-use verification Iran export controls | Bureau of Industry and Security
No license exceptions are available for Iran, eliminating the standard relief mechanisms found in other sanctions programs Iran export controls | Bureau of Industry and Security
The temporary nature of general licenses (GL U expiring April 19, 2026; GL V expiring May 24, 2026; GL X expiring August 21, 2026) demonstrates that even authorized activities are time-limited and subject to reversal or non-renewal, creating severe business continuity risks Issuance of Iran-related General License | Office of Foreign Assets Control
The terms "digital assets" and "cryptocurrency" do not appear in the regulatory framework, indicating that the regulations have not been updated to address this asset class specifically, leaving it to be governed by general sanctions provisions that were not designed for digital assets Federal Register :: Iranian Transactions and Sanctions Regulations
The lack of tax guidance for virtual assets creates additional uncertainty for any business considering engagement, as the financial implications of authorized transactions cannot be properly assessed Federal Register :: Publication of Iran-Related Web General Licenses U and V
The practical reality is that engaging in cryptocurrency or digital asset activities involving Iran carries extreme legal risk, with no clear licensing pathway, no compliance guidance specific to digital assets, and a licensing policy that presumptively denies non-humanitarian applications Iran export controls | Bureau of Industry and Security
Federal Register :: Publication of Iran-Related Web General Licenses U and V
Issuance of Iran-related General License | Office of Foreign Assets Control
Federal Register :: Iranian Transactions and Sanctions Regulations
Licensing | Bureau of Industry and Security
Iran export controls - Licensing
Federal Register :: Publication of Covid-Related Web General License Related to Iranian Transactions and Sanctions Regulations and Global Terrorism Sanctions Regulations
eCFR :: 31 CFR Part 560 Subpart E -- Licenses, Authorizations, and Statements of Licensing Policy
Federal Register :: Publication of Iranian Transactions and Sanctions Regulations Web General License P
U.S. Treasury Issues Iran General License D-2 to Increase Support for Internet Freedom | U.S. Department of the Treasury
AML/KYC Requirements
FATF Blacklisting: Iran is currently on the FATF's "Public Statement – High-Risk Jurisdictions Subject to a Call for Action," meaning it is subject to a call for countries to apply enhanced due diligence and, in the most serious cases, countermeasures to protect the international financial system from the ongoing money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from Iran. This significantly impacts any international VASP's ability or willingness to operate in or with Iran.
International Sanctions: Iran is under extensive international sanctions (primarily from the US), which prohibit most financial transactions involving Iranian entities or individuals, further complicating VASP operations.
Evolving Domestic Stance: Iran's stance on cryptocurrencies has evolved from outright bans to allowing regulated mining and exploring the use of crypto for bypassing sanctions (e.g., import payments), while generally maintaining strict controls over public trading and use for domestic payments.
Legislation Name: "Law on Combating Money Laundering" (Qanun Mobaraze ba Pulshui), initially passed in 2008 and amended in 2019.
Purpose: This is the foundational AML law in Iran, establishing general obligations for reporting entities (which would include any authorized financial service providers, including VASPs if fully integrated into the financial system).
Key Provisions: Defines money laundering offenses, sets reporting obligations, establishes the Supreme Council for Combating Money Laundering and Financing of Terrorism, and outlines the role of the Financial Intelligence Unit (FIU).
Legislation Name: "Law on Combating Money Laundering" (Qanun Mobaraze ba Pulshui), initially passed in 2008 and amended in 2019.
Purpose: Addresses the financing of terrorism. Any VASP, if operating, would be subject to its provisions, especially regarding sanctions screening and suspicious transaction reporting.
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies. Its stance has largely been to ban banks and financial institutions from dealing in cryptocurrencies and to restrict their use for domestic payments. The CBI is also involved in developing a national digital currency (CBDC).
The CBI is the primary regulator for financial services and has issued directives concerning virtual assets.
Early Stance (2018): The CBI initially banned all dealings in cryptocurrencies by banks and financial institutions, citing money laundering risks.
Evolving Stance (2019-Present): The CBI later allowed cryptocurrency mining as an industrial activity, requiring miners to obtain licenses and sell their mined crypto to the CBI for import financing. However, the use of cryptocurrencies for domestic payments is generally prohibited, and public trading platforms for major cryptocurrencies face significant restrictions or are not officially sanctioned in a broad retail sense.
Applying Existing AML: The CBI's stance implies that any entity authorized to deal with virtual assets (e.g., licensed miners selling to CBI, or potentially future regulated exchanges) would be subject to existing AML/CFT laws and CBI directives regarding KYC, transaction monitoring, and reporting.
National ID number (National Code for Iranians)
Verification through official documents (e.g., National ID card, passport).
Legal form (e.g., company, partnership)
Registered address and principal place of business
Details of directors, senior management, and beneficial owners (shareholders owning 25% or more, or controlling persons).
Verification through official corporate documents (e.g., certificate of incorporation, articles of association).
Understanding the purpose for which the customer intends to use the VASP's services (e.g., mining, trading, remittance, specified payment).
Understanding the expected nature and volume of transactions.
Scrutinizing transactions throughout the course of the relationship to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.
Regularly updating customer information and risk assessment.
Required for high-risk customers, politically exposed persons (PEPs), and transactions identified as high-risk (e.g., large value transactions, complex structures, transactions from high-risk jurisdictions).
Includes measures like obtaining additional information on the customer and their source of funds/wealth, obtaining senior management approval for the relationship, and increased monitoring.
Especially critical for virtual assets, VASPs would need to establish the legitimate source of funds used to acquire virtual assets and the source of wealth of the customer.
Screening customers against domestic (if any specific to crypto) and international sanctions lists (though international sanctions might preclude VASP interaction altogether).
Obligation to Report: VASPs, if authorized, would be obligated to report any suspicious transactions or activities to the Financial Intelligence Unit (FIU). This includes transactions that are inconsistent with a customer's known legitimate activities, or those that suggest money laundering, terrorist financing, or proliferation financing.
FIU: The primary FIU in Iran is located within the Secretariat of the High Council for Combating Money Laundering and Financing of Terrorism, which is part of the Ministry of Economy and Financial Affairs.
No Tipping-Off: VASPs are prohibited from informing the customer or any third party that an STR has been filed.
Transaction Records: All transaction data, including dates, amounts, types of assets, sender/receiver information, and IP addresses.
CDD Records: All documents and data obtained during the CDD process (identification, verification, risk assessment).
STRs: Copies of all suspicious transaction reports filed.
Duration: Records are typically required to be kept for at least five to ten years after the business relationship has ended or the transaction has occurred.
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies. Its stance has largely been to ban banks and financial institutions from dealing in cryptocurrencies and to restrict their use for domestic payments. The CBI is also involved in developing a national digital currency (CBDC).
Role: The main financial regulator, responsible for licensing, supervision, and issuing specific directives regarding virtual assets and their interaction with the financial system.
Role: The main policy-making body for AML/CFT in Iran, providing strategic direction and overseeing the implementation of the LCML and LCFT. Its secretariat houses the FIU.
URL: Information is typically integrated with the Ministry of Economy and Financial Affairs.
Role: Broader oversight of financial policy and the umbrella ministry under which the High Council and FIU operate.
No General Retail VASP Market: There is no established, government-sanctioned, retail-facing VASP market (like open crypto exchanges) for the general public in Iran due to the general ban on crypto for payments and significant restrictions on trading.
Focus on Licensed Mining: The primary regulated VASP-related activity is licensed cryptocurrency mining, where mined crypto must be sold to the CBI or authorized entities for specific purposes (like import financing). These licensed entities would be subject to strict AML/CFT checks by the CBI.
International Isolation: Due to FATF blacklisting and international sanctions, it is virtually impossible for any reputable international VASP to legally offer services to Iranian citizens or entities, regardless of Iran's domestic regulations. Doing so would expose them to severe regulatory and reputational risks.
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies. Its stance has largely been to ban banks and financial institutions from dealing in cryptocurrencies and to restrict their use for domestic payments. The CBI is also involved in developing a national digital currency (CBDC).
Ministry of Industry, Mines, and Trade (MIMT): Responsible for licensing and regulating cryptocurrency mining operations.
Securities and Exchange Organization (SEO): Traditionally regulates securities in Iran under the Securities Market Law of the Islamic Republic of Iran (2005). However, its direct role in classifying private cryptocurrency tokens as securities for public offerings is minimal, largely because such offerings are not openly permitted or have been discouraged by the CBI.
National Cyberspace Center (NCC) / Economic Council / Parliament: These bodies are involved in drafting and approving broader legislation concerning digital assets and cyberspace, which may eventually include more detailed provisions for crypto classification.
Traditional Securities Law: Iran's Securities Market Law of 2005 defines "securities" generally to include shares, bonds, mutual fund units, and other instruments that grant ownership rights, debt claims, or partnership interests.
Lack of Specific Crypto Guidance: The challenge with private crypto tokens is that they haven't been explicitly brought under this existing framework for public offerings. The regulatory emphasis has been on banning or heavily restricting their use rather than establishing a formal classification process for investor protection in a public market context.
Implicit Interpretation (Hypothetical): If a private token were to be issued seeking public investment with an expectation of profit derived from the efforts of others (similar to the Howey test's criteria), it would likely face significant scrutiny and potential prohibition under existing financial regulations, rather than being formally classified and regulated as a security by the SEO. The primary concern would be capital flight, AML, and monetary stability, as opposed to investor protection in a nascent token market.
No specific private crypto tokens are formally recognized and regulated as securities for public offering in Iran.
National Digital Currency (CBDC): The CBI has been developing a national digital currency, often referred to as "Paymon" or the "Digital Rial." This is a central bank-issued currency, not a public investment security, intended for domestic payments and interbank settlements.
Mining as a Regulated Activity: The tokens acquired through licensed mining operations (e.g., Bitcoin, Ethereum) are treated as commodities or assets that can be used for specific purposes (like paying for imports), but the act of mining itself is a licensed industrial activity, and the tokens are not classified as securities by the MIMT in this context.
Tokens for International Trade: In 2022, a law was passed allowing the use of cryptocurrencies for import payments. These tokens are treated as a means of exchange for international trade, not as domestic securities.
There are no formalized registration or exemption requirements for private crypto token issuers seeking to conduct public offerings in Iran. This is because such activities are generally not permitted or are severely restricted.
Any entity attempting to launch an Initial Coin Offering (ICO) or similar token sale to the Iranian public would likely face regulatory challenges, including potential bans or legal action from the CBI, given the restrictions on cryptocurrency activities by financial institutions and the general public.
The focus of Iranian authorities is on preventing unauthorized financial activities and capital flight, not on providing a framework for public token offerings.
No formal rules exist for the secondary trading of private crypto tokens as securities.
General Cryptocurrency Trading: While a full ban on individuals owning or trading cryptocurrencies is difficult to enforce, the CBI has repeatedly warned against their use and banned financial institutions from dealing with them.
Exchanges: Many local crypto exchanges operate in a legal grey area, requiring users to comply with AML/KYC norms, often to avoid outright shutdowns. However, these are typically platforms for exchanging general cryptocurrencies (like Bitcoin for Rial), not regulated securities trading platforms for tokenized assets.
Licensed Platforms: The government has indicated a desire to license exchanges, primarily to control the flow of capital and ensure AML compliance, rather than regulating a securities market for tokens.
Unauthorized Crypto Exchange Operations: Several arrests have been made, and exchanges have been shut down for operating without proper authorization or for facilitating illegal activities (like capital flight or prohibited domestic payments).
Use of Crypto for Domestic Payments: Individuals and businesses attempting to use cryptocurrencies for everyday transactions within Iran have faced warnings and potential legal action, as this goes against the CBI's prohibition on crypto as legal tender.
Unlicensed Mining Operations: Authorities frequently crack down on unlicensed crypto mining farms, especially those illegally using subsidized electricity.
Capital Flight: Any significant movement of capital out of the country via cryptocurrencies is a major concern and subject to stringent enforcement.
2018: The CBI officially banned Iranian banks and financial institutions from dealing in cryptocurrencies, citing money laundering and financing of terrorism concerns.
Ongoing (2020-Present): Numerous reports of police raids on illegal crypto mining operations, resulting in confiscation of equipment and arrests.
Ongoing: Warnings issued by the CBI and law enforcement against illegal cryptocurrency exchanges and platforms that do not adhere to AML/KYC regulations or facilitate prohibited activities. The judiciary has often highlighted the risks associated with investing in unregulated crypto schemes.
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies. Its stance has largely been to ban banks and financial institutions from dealing in cryptocurrencies and to restrict their use for domestic payments. The CBI is also involved in developing a national digital currency (CBDC).
The CBI's stance on prohibiting banks from dealing with cryptocurrencies was formalized in a circular in April 2018. While a direct English-language URL to the official circular is difficult to obtain, it has been widely reported by reputable news agencies.
General CBI website (Farsi): https://www.cbi.ir/ - Navigate to "News" or "Circulars" for updates, which would need translation.
Ministry of Industry, Mines, and Trade (MIMT): Responsible for licensing and regulating cryptocurrency mining operations.
The MIMT issued regulations in 2019 and subsequent amendments for licensing cryptocurrency mining farms, treating it as an industrial activity. These regulations detail energy tariffs, licensing procedures, and export requirements for mined crypto.
General MIMT website (Farsi): https://www.mimt.gov.ir/ - Specific regulations on crypto mining are usually found in their "Laws and Regulations" section, requiring translation.
Approved in 2022, allowing registered importers to use cryptocurrencies to pay for imports. This was a significant shift, but it specifically targets international trade, not domestic securities offerings.
Often reported by Iranian English news outlets like Tehran Times or Mehr News Agency.
Securities Market Law of the Islamic Republic of Iran (2005):
This is the fundamental law governing securities in Iran. While it doesn't mention crypto, it's the basis for what would constitute a security if tokens were brought under the SEO's purview.
Often referenced in legal analyses; official English translations are scarce.
Draft Comprehensive Digital Currency Regulation / Law on the Organization of Cyberspace:
Various drafts have been under discussion by different governmental bodies (Parliament, Economic Council, National Cyberspace Center) for several years. These drafts are expected to provide a more holistic framework for digital assets, including potential classifications, but are still in progress and subject to change.
News reports often provide updates on these drafts; direct official URLs are not usually public until final approval.
Whether Adopted: No, the FATF Travel Rule has not been adopted in Iran. Iran remains on the FATF's list of High-Risk Jurisdictions due to its failure to enact the Palermo and TF Conventions and other fundamental deficiencies. Implementing a specific measure like the Travel Rule is not on the agenda when the foundational AML/CFT framework is not in place.
Effective Date: Not applicable. Since the rule has not been adopted, there is no effective date.
Threshold Amounts: Not applicable. Without adoption, there are no defined threshold amounts for the Travel Rule.
Which VASPs are Covered: Not applicable. There is no regulatory framework in Iran that mandates VASPs to comply with the FATF Travel Rule. Domestic regulations regarding virtual assets are primarily focused on controlling their use within the country and have not incorporated international AML/CFT standards to this extent.
Technical Implementation Requirements: Not applicable. No technical implementation requirements exist for the Travel Rule in Iran.
For Iran (at the international level): The primary "penalty" for Iran's non-compliance with FATF recommendations (including the implicit non-implementation of the Travel Rule) is its continued presence on the FATF blacklist. This results in severe economic sanctions from the international community, financial isolation, difficulty accessing global financial systems, and increased scrutiny and due diligence requirements for any entity attempting to transact with Iranian entities. International financial institutions are strongly discouraged from engaging in transactions with Iran.
FATF Public Statement on High-Risk Jurisdictions Subject to a Call for Action (February 2020, still current): The FATF stated that "Given Iran’s failure to enact the Palermo and TF Conventions in line with the FATF Standards, the FATF suspended its call for members and urged all members to apply counter-measures and enhanced due diligence in February 2020. Iran will remain on the FATF statement on High-Risk Jurisdictions Subject to a Call for Action until the full Action Plan has been completed."
URL: https://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/call-for-action-february-2020.html (This is the last comprehensive update regarding Iran's status on the blacklist, which remains unchanged).
For Domestic Entities in Iran (related to crypto activities): While not directly linked to the Travel Rule, Iran has implemented domestic regulations concerning virtual assets, primarily focused on control and preventing their use for illicit purposes or circumventing sanctions.
For example, in 2018, the Central Bank of Iran (CBI) initially banned the use of cryptocurrencies by banks and financial institutions, though this stance has evolved somewhat, especially concerning crypto mining for electricity export. The use of cryptocurrencies for payments within the country remains largely prohibited.
Specific Legislation/Guidance (Domestic): Finding direct, current, and publicly accessible English translations of specific Iranian legislation on virtual assets with URLs can be challenging due to language barriers and the nature of Iranian legal publications. However, news reports and analyses often cite:
Central Bank of Iran (CBI): The primary regulator for financial and monetary affairs, including cryptocurrencies. Its stance has largely been to ban banks and financial institutions from dealing in cryptocurrencies and to restrict their use for domestic payments. The CBI is also involved in developing a national digital currency (CBDC).
Governmental Decrees: The Iranian government has also issued decrees, particularly concerning the licensing of cryptocurrency mining operations.
General Penalties: Any individual or entity engaging in unauthorized cryptocurrency activities (e.g., using crypto for payments, operating an unlicensed exchange, or engaging in money laundering using crypto) would be subject to penalties under existing Iranian laws related to financial crimes, foreign exchange regulations, and unlicensed financial activities. These penalties could include fines, imprisonment, and asset confiscation. However, these are domestic penalties for domestic illicit activities and not specific penalties for non-compliance with the international FATF Travel Rule.
Travel Rule
Iran is subject to FATF High-Risk Jurisdiction status with countermeasures called for, meaning the country does not have a compliant AML/CFT framework and international entities must apply enhanced scrutiny to Iranian counterparties, including virtual asset service providers (VASPs) Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Iran's domestic legal framework for cryptocurrency regulation is not recognized by FATF as compliant, and the country lacks the comprehensive AML/CFT legislation necessary to implement travel-rule standards Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
No Iranian licensing regime for VASPs has been established that meets international standards; the FATF has explicitly identified Iran as requiring countermeasures, including prohibiting financial institutions and VASPs from establishing new correspondent relationships with Iranian entities Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The practical reality is that Iran is internationally isolated in the digital asset space, with global financial institutions directed to treat Iranian VASPs as high-risk due to inadequate AML/CFT systems FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
Iranian financial institutions and VASPs face international sanctions and countermeasures, and the FATF has called for effective countermeasures since 2020, reaffirmed in February 2025 and again in February 2026 Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The travel-rule framework, as defined by FATF Recommendation 16, requires VASPs to share originator and beneficiary information for virtual asset transfers; Iran has not implemented this requirement, and its inability to comply has contributed to its continued high-risk designation Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The Financial Action Task Force (FATF) is the international standard-setting body for AML/CFT/CPF; on October 11, 2007, FATF identified Iran as the only country with significant AML/CFT vulnerabilities requiring enhanced due diligence Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
FATF continues to list Iran on its "High-Risk Jurisdictions Subject to a Call for Action" list, noting that Iran has significant strategic deficiencies in its AML/CFT/CPF regimes Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF public statement on Iran reminds all jurisdictions of their obligations under FATF standards to address proliferation financing risks emanating from Iran and urges all jurisdictions to apply effective countermeasures Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF called on all jurisdictions to impose effective countermeasures on Iran, specifically requiring financial institutions to review, amend, or if necessary terminate correspondent relationships with Iranian banks or limit business relationships or financial transactions with Iran Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The FATF countermeasures are designed to protect the international financial system from ongoing money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from Iran Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers existing U.S. sanctions with respect to the Government of Iran, including Iranian Government-owned banks, and other sanctions imposed on Iranian entities linked to terrorist activity and proliferation of weapons of mass destruction Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The Financial Crimes Enforcement Network (FinCEN) issued advisory FIN-2007-A001 in 2007 to inform U.S. financial institutions about the money laundering threat involving illicit Iranian activity, alerting them to the risk of deceptive practices involving shell companies, intermediaries, and requests to remove identifying information from transactions Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
United Nations Security Council Resolution (UNSCR) 1737 of December 23, 2006, requires all member states to prevent the provision to Iran of financial assistance, investment, brokering or other services, and the transfer of financial resources or services related to proliferation-sensitive nuclear activities Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
UNSCR 1747 of March 24, 2007, further addressed Iran's ongoing nuclear program and required member states to implement activity-based financial prohibitions Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF has advised jurisdictions to consider all customers and transactions associated with Iran as a primary risk determinant for the purposes of applying risk-based identification and enhanced scrutiny with respect to high-risk customers and transactions that may be related to activity prohibited by UNSCR 1737 Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Iran is mentioned in the 2026 FinCEN advisory as remaining on the FATF High-Risk Jurisdictions list with four specific countermeasures, including refusing the establishment of subsidiaries or branches of financial institutions or VASPs from Iran and prohibiting financial institutions from establishing branches in Iran Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF in February 2025 reaffirmed countermeasures against Iran for the terrorist financing risk emanating from that country FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
Iran's lack of a comprehensive anti-money laundering and combating the financing of terrorism (AML/CFT) regime represents a significant vulnerability within the international financial system, as determined by FATF Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF statement of concern dated October 11, 2007, noted that "FATF members are advising their financial institutions to take the risk arising from deficiencies in Iran's AML/CFT regime into account for enhanced due diligence" Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Iran's deficiencies were also identified in the 2006 International Monetary Fund Article IV Consultation Report for Iran Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF called upon Iran "to address on an urgent basis its AML/CFT deficiencies" Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The United States has designated Iranian entities, including Iranian state-owned Bank Saderat, under Executive Order 13224, which targets terrorists and those providing financial, technological, or material support to terrorists or acts of terrorism Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
Iran remains subject to the FATF statement that called for countries throughout the world to strengthen measures to protect their financial sectors from risks posed by Iran Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The FATF is a 34-member inter-governmental body whose purpose is the development and promotion of policies to combat money laundering and terrorist financing Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The United Nations continues to adopt several resolutions implementing economic and financial sanctions, and Member States are bound by the provisions of these UN Security Council Resolutions (UNSCRs) Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
There is no recognized Iranian licensing regime for virtual asset service providers (VASPs) under the international AML/CFT framework; the FATF has not certified or recognized any Iranian licensing mechanism as compliant with its standards Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF requires jurisdictions to apply effective countermeasures on Iran, including "refusing the establishment of subsidiaries or branches or representative offices of financial institutions from the country concerned or otherwise taking into account the fact that the relevant financial institution or virtual asset service provider is from a country that does not have adequate AML/CFT systems" Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
No Iranian VASP licensing authority, application process, timeline, structural requirements, or capital requirements have been established; no Iranian regulator responsible for licensing cryptocurrency businesses has been identified Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The FATF countermeasures include "prohibiting financial institutions from establishing branches or representative offices in the country concerned, or otherwise taking into account the fact that the relevant branch or representative office would be in a country that does not have adequate AML/CFT systems" Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Zero entities have been licensed under any internationally recognized Iranian VASP licensing framework; no licensed cryptocurrency exchanges or virtual asset businesses in Iran have been documented FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
Additional FATF countermeasures include "on a risk basis, limiting business relationships or financial transactions, including virtual asset transactions, with the identified country or persons in the country concerned" Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF also calls for "prohibiting financial institutions and virtual asset service providers from establishing new correspondent relationships and requiring them to undertake a risk-based review of existing correspondent relationships with financial institutions and virtual asset service providers in the country concerned" Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Any business operating as a VASP in Iran would face automatic high-risk designation internationally, and the FATF has explicitly stated that the fact that a financial institution or VASP is from Iran is itself a signal of inadequate AML/CFT systems Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The FATF has identified that Iran's lack of a comprehensive anti-money laundering and combating the financing of terrorism (AML/CFT) regime represents a significant vulnerability within the international financial system Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
FATF has called on all jurisdictions to impose effective countermeasures on Iran, such as requiring financial institutions to review, amend, or if necessary terminate correspondent relationships with Iranian banks or limiting business relationships or financial transactions with Iran Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
FATF members are advised to take the risk arising from deficiencies in Iran's AML/CFT regime into account for enhanced due diligence Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Financial institutions should be particularly aware that there may be an increased effort by Iranian entities to circumvent international sanctions and related financial community scrutiny through the use of deceptive practices involving shell companies and other intermediaries or requests that identifying information be removed from transactions Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Such deceptive practices may originate in Iran or Iranian free trade zones subject to separate regulatory and supervisory controls, including Kish Island Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF has advised jurisdictions to consider all customers and transactions associated with Iran as a primary risk determinant for the purposes of applying risk-based identification and enhanced scrutiny with respect to high-risk customers and transactions Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF countermeasure requires that on a risk basis, jurisdictions limit business relationships or financial transactions, including virtual asset transactions, with Iran or persons in Iran Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
No Iran-specific CDD, EDD, STR reporting, record retention, beneficial ownership, or PEP screening requirements exist because Iran has not established a recognized AML/CFT framework meeting FATF standards Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The FATF has declared that Iran's lack of effort to combat terrorist financing continues to pose a serious threat to the integrity of the international financial system Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The FATF urged Iran to take urgent action to address these concerns, and the failure to do so has resulted in continued calls for countermeasures Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The FATF's February 2026 statement specifically highlights that Iran is subject to a call for action and that the organization continues to call on jurisdictions to apply effective countermeasures, including measures targeting virtual asset service providers Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The U.S. Department of the Treasury has designated Iranian entities under Executive Order 13224, including Iranian state-owned Bank Saderat, which targets terrorists and those providing financial, technological, or material support to terrorists or acts of terrorism Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The FATF called on all countries to apply countermeasures on North Korea due to ongoing money laundering, terrorist financing, and weapons of mass destruction proliferation financing risks; Iran was separately and specifically identified for countermeasures Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
The FATF public statement on Iran reminds all jurisdictions of their obligations under the FATF standards to address proliferation financing risks emanating from Iran and reiterates the call for action to its members to apply effective countermeasures Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
In October 2008, the FATF expressed particular concern about Iran's lack of effort to combat terrorist financing and declared that this continues to pose a serious threat to the integrity of the international financial system Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The United States has repeatedly expressed deep concerns about Iran's financial and material support to deadly terrorist groups Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
Sustained action against Iran by the FATF, United Nations Security Council, European Union and others verifies that the international community's grave concerns about Iran's conduct transcend borders and politics Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
The FATF's call for countermeasures on Iran was reaffirmed in February 2025, with Secretary of the Treasury Scott Bessent stating that "The United States welcomes the FATF's reaffirmation of countermeasures against Iran for the terrorist financing risk emanating from that country" FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
In February 2020, Secretary Steven T. Mnuchin stated that "Iran claimed it was finally ready to implement basic controls to counter illicit finance, but the regime has failed to live up to its commitments" Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
No tax guidance for virtual assets in Iran has been issued; available information focuses exclusively on Iran's AML/CFT deficiencies and international countermeasures, not domestic tax policy Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
No information about Iranian income tax, capital gains tax, or VAT treatment of cryptocurrency or virtual assets is available Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
No Iranian tax authority has been identified for purposes of virtual asset taxation FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
Iran's continued designation as a High-Risk Jurisdiction Subject to a Call for Action means that any VASP operating in or from Iran faces automatic enhanced due diligence from international counterparties Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
A business operating in Iran's cryptocurrency sector would face the FATF countermeasure requiring jurisdictions to refuse the establishment of subsidiaries, branches, or representative offices of financial institutions or VASPs from Iran Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Iranian VASPs would be subject to the FATF countermeasure requiring jurisdictions to prohibit financial institutions and VASPs from establishing new correspondent relationships with Iranian entities Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The risk of deceptive practices, including shell companies, intermediaries, and stripping identifying information from transactions, has been identified as a specific concern for Iranian entities attempting to circumvent sanctions Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Deceptive efforts may originate in Iran or Iranian free trade zones subject to separate regulatory and supervisory controls, including Kish Island Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The practical reality is that Iran has no internationally recognized cryptocurrency regulatory framework, no compliant VASP licensing regime, and no travel-rule implementation recognized by FATF Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
Iran's FATF action plan obligations have not been fulfilled, and the country continues to face the same four countermeasures identified by FATF, including measures that specifically address virtual asset transactions Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Any financial institution or VASP that does not apply adequate measures with respect to transactions involving Iran faces the risk of non-compliance with FATF standards and domestic regulatory obligations Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The absence of a recognized Iranian regulatory framework for VASPs creates significant legal uncertainty for any business seeking to operate in the cryptocurrency sector in Iran, particularly regarding compliance with international AML/CFT obligations Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
The FATF has warned that the fact that a relevant financial institution or VASP is from a country that does not have adequate AML/CFT systems, such as Iran, should be considered in risk assessments Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
The travel-rule requirement, which mandates that VASPs obtain, hold, and transmit originator and beneficiary information for virtual asset transfers, cannot be effectively implemented in Iran without a compliant AML/CFT framework, which FATF has consistently found to be absent Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Iranian entities may attempt to conceal their identity in transactions, and financial institutions are warned that requests to remove identifying information from transactions may be an indicator of illicit activity Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity | FinCEN.gov
Treasury Responds to FATF's Call for Strengthened Measures Against Iran | U.S. Department of the Treasury
Financial Action Task Force (FATF) Calls for Countermeasures on Iran, Evaluates U.S. AML Framework, Releases Digital Identity Guidance | U.S. Department of the Treasury
FATF Advances Work Combatting Proliferation Financing, Reaffirms Countermeasures Against Iran | U.S. Department of the Treasury
Tax Reporting
Banned for Domestic Payments: The Central Bank of Iran (CBI) has repeatedly banned the use of cryptocurrencies for domestic payments and transactions within Iran.
Restrictions on Domestic Exchanges/Trading: While some local exchanges operate, individual trading and holding of cryptocurrencies are generally discouraged, tightly regulated, or even de facto illegal for retail investors for speculative purposes by the CBI. There is no clear legal framework for individuals to legally trade cryptocurrencies on a large scale.
Legal for Imports (Under Specific Conditions): In 2022, Iran officially approved the use of cryptocurrencies for import payments as a way to circumvent international sanctions. This is typically for businesses and under strict governmental oversight.
Regulated Mining: Crypto mining is recognized as a legal industrial activity in Iran but requires licenses from the Ministry of Industry, Mine and Trade and is subject to specific regulations, including higher electricity tariffs.
Status: Legal, regulated industrial activity requiring licenses.
Income Tax: Licensed crypto mining operations are treated as businesses and are subject to standard corporate income tax rates. The income generated from mining (e.g., block rewards converted to fiat, or the sale of mined crypto) is considered business income.
Corporate Income Tax Rates: These vary based on factors like company type, profit levels, and whether they are listed on the stock exchange. Generally, the standard corporate income tax rate for Iranian companies is 25% of taxable income.
If the mining operation is considered to be providing a service (e.g., validating transactions) or selling its "product" (mined crypto) within Iran, it could potentially be subject to VAT.
However, the nature of crypto mining revenue (block rewards) often makes direct VAT application complex, especially if the "service" isn't directly sold to an identifiable domestic consumer.
If a mining farm sells its mined cryptocurrencies, and this is considered a sale of goods or services, then 9% VAT (the standard rate in Iran) could apply to the fiat equivalent value. However, clarification on this specific point for crypto sales is often lacking.
Reporting Requirements: Licensed mining businesses must comply with standard Iranian accounting practices, keep proper records, and file annual tax returns with the Iranian National Tax Administration (سازمان امور مالیاتی کشور).
Other Costs: Miners face significantly higher electricity tariffs compared to regular industrial users, which is effectively a form of indirect taxation or regulatory cost.
Status: Highly restricted, often considered illegal or at least strongly discouraged by the Central Bank for domestic speculative purposes. This makes a formal tax framework for individual gains largely moot.
There is no specific capital gains tax framework for individuals trading cryptocurrencies in Iran. Since the activity itself is largely prohibited or severely restricted for individuals, the government has not established a mechanism to tax these gains.
If an individual somehow realizes significant gains and brings them into the traditional financial system, they could theoretically be subject to scrutiny and potentially taxed under general income tax laws if deemed "undeclared income," but this is speculative and not based on a specific crypto capital gains tax.
Income Tax: No specific income tax provisions for individual crypto trading.
VAT/GST Treatment: Not applicable for individual trading activities.
Reporting Requirements: None specifically established for individuals trading crypto, precisely because the activity is not officially recognized or encouraged. Any attempts to declare such income would likely expose the individual to questions about the legality of their activities.
Status: Legalized for import payments, under specific governmental and CBI oversight.
Income Tax: If an Iranian business uses cryptocurrency to pay for imports or receive payments for exports, the underlying commercial transaction (import/export of goods/services) is subject to standard corporate income tax. Any profit or loss from the business activity itself is taxed in Iranian Rial equivalent.
Gains or losses arising from the fluctuation in the cryptocurrency's value before it's used or converted for the trade are generally absorbed into the company's overall profit and loss for tax purposes, as part of their foreign currency or asset management.
VAT/GST Treatment: VAT applies to the goods or services being imported or exported, not typically to the cryptocurrency itself as a payment method. Imports are generally subject to VAT upon entry. Exports are typically zero-rated.
Reporting Requirements: Businesses must comply with all standard import/export regulations, customs declarations, and financial reporting requirements, including accounting for cryptocurrency transactions in their books (valued in IRR at the time of transaction) and reporting to the Tax Affairs Organization. These transactions are likely subject to heightened scrutiny.
No Comprehensive Law: Iran does not have a comprehensive, dedicated "Cryptocurrency Tax Law" that details specific rates and rules for all virtual asset activities like some Western countries.
Existing Regulations: The existing regulations primarily focus on:
Licensing and operation of crypto mining farms: These regulations dictate how miners must operate and contribute to the grid, indirectly affecting their taxable base.
Bans and restrictions on domestic crypto use/trading: These effectively prevent the establishment of a formal tax framework for individual trading.
Framework for using crypto in international trade: This governs how businesses can use crypto for cross-border transactions under government oversight, fitting it into existing trade and corporate tax laws.
Notes: This is the primary tax authority. While you won't find a dedicated "Cryptocurrency Tax Guide" page, any taxation of legal crypto activities (like mining business profits) would fall under their general corporate income tax and VAT regulations. Their website is predominantly in Farsi.
Notes: The CBI is the main regulatory body for financial instruments and sets the legal status for cryptocurrencies. Their official announcements (often found in their news section) are crucial for understanding what is permissible and what is banned, thereby indirectly dictating what can be taxed.
Notes: This ministry is responsible for issuing licenses for cryptocurrency mining operations. Their regulations, though not directly tax-related, define the legal existence of mining businesses that are subsequently subject to tax.
Custody Requirements
Custody regulation data collection in progress.
Stablecoin Regulation
Stablecoin regulation data collection in progress.
Securities Classification
Iran has not established a specific legal framework for cryptocurrency or digital asset securities as of 2025–2026, and no Iranian regulatory authority has issued a licensing regime for crypto securities Iran Sanctions FAQ - Office of Foreign Assets Control
The only applicable rules for Iran-based digital asset activity are U.S. sanctions regulations administered by the Office of Foreign Assets Control (OFAC) at the Department of the Treasury, which restrict U.S. persons and impose blocking requirements on Iranian financial institutions Federal Register :: Iranian Transactions and Sanctions Regulations
No Iranian government agency has been named as a securities regulator for digital assets, and no licensing pathway exists for crypto exchanges, custodians, or digital asset securities issuers within Iran Federal Register :: Iranian Transactions Regulations
In practice, no entity has secured any form of official authorization for digital asset securities activity in Iran, and the practical reality is that crypto securities businesses cannot operate legally or with regulatory certainty 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The primary legal constraint governing crypto-related activity is the Iranian Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560, which imposes comprehensive trade and financial sanctions on Iran and prohibits most transactions involving Iranian accounts and securities services Iran Sanctions FAQ - Office of Foreign Assets Control
The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is the primary authority that regulates transactions involving Iran, including any digital asset securities activity with Iranian nexus; OFAC's website is https://ofac.treasury.gov Federal Register :: Iranian Transactions and Sanctions Regulations
The Iranian Transactions and Sanctions Regulations (ITSR) are codified at 31 CFR Part 560 and were reissued in their entirety on October 22, 2012, effective the same date Federal Register :: Iranian Transactions Regulations
The ITSR implement Executive Order 13599 of February 5, 2012, which blocks property of the Government of Iran and Iranian financial institutions, and subsections 1245(c) and (d)(1)(B) of the National Defense Authorization Act for Fiscal Year 2012 (NDAA) Federal Register :: Iranian Transactions Regulations
The ITSR are separate from the Iranian Financial Sanctions Regulations, 31 CFR Part 561, which were reissued in their entirety on February 27, 2012, and implement the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Federal Register :: Iranian Transactions Regulations
On May 17, 2024, OFAC published a final rule amending the ITSR to incorporate General License D-2, which relates to the export, reexport, and provision of certain services, software, and hardware incident to communications over the internet Federal Register :: Iranian Transactions and Sanctions Regulations
The original Iranian Transactions Regulations trace back to Executive Order 12613 of October 29, 1987, issued under the International Security and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-9), which prohibited the importation of Iranian-origin goods and services Federal Register :: Iranian Transactions Regulations
Subsequent executive orders include Executive Order 12957 (March 15, 1995), which declared a national emergency regarding Iran and imposed prohibitions on certain transactions related to Iranian petroleum resources, and Executive Order 12959 (May 6, 1995), which imposed comprehensive trade and financial sanctions on Iran without blocking sanctions Federal Register :: Iranian Transactions Regulations
Executive Order 13059 (August 19, 1997) consolidated and clarified the previous orders governing Iran sanctions Federal Register :: Iranian Transactions Regulations
The ITSR was amended on March 10, 2010, to add a general license in § 560.540 authorizing the exportation of certain services and software incident to the exchange of personal communications over the internet, provided such services were publicly available at no cost to the user Federal Register :: Iranian Transactions and Sanctions Regulations
On May 30, 2013, OFAC issued General License D under the ITSR, authorizing the export or reexport, directly or indirectly, from the United States or by U.S. persons, to persons in Iran of additional services, software, and hardware incident to personal communications, including fee-based versions Federal Register :: Iranian Transactions and Sanctions Regulations
General License D-1 was issued on February 7, 2014, replacing GL D, and General License D-2 was issued on September 23, 2022, replacing GL D-1; GL D-2 removed the "personal" qualifier from the authorization and added modern services including social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services Federal Register :: Iranian Transactions and Sanctions Regulations
OFAC's regulations consider that operating a bank account for an individual or company in Iran constitutes an export of services to Iran in violation of the Iranian Transactions Regulations, and such accounts are restricted rather than blocked Iran Sanctions FAQ - Office of Foreign Assets Control
U-Turn payments for Iran have been prohibited as of November 10, 2008 Iran Sanctions FAQ - Office of Foreign Assets Control
The Iran Sanctions FAQ specifies that accounts with a W-8 form showing an address in Iran should be considered restricted in the absence of information proving the account holder is not in Iran Iran Sanctions FAQ - Office of Foreign Assets Control
Clients who are visiting Iran but are not ordinarily resident in Iran do not require account restriction Iran Sanctions FAQ - Office of Foreign Assets Control
OFAC's sanctions under the ITSR apply to U.S. persons wherever located, including overseas branches of U.S. financial institutions Iran Sanctions FAQ - Office of Foreign Assets Control
The FATF (Financial Action Task Force) status of Iran is not addressed within the provided source texts, and no Moneyval or FATF evaluation is mentioned in the supplied materials Federal Register :: Iranian Transactions Regulations
The Iranian Financial Sanctions Regulations define "U.S. financial institutions" to include depository institutions, banks, savings banks, money service businesses, trust companies, insurance companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment companies, employee benefit plans, and U.S. holding companies or affiliates Iran Sanctions FAQ - Office of Foreign Assets Control
The Iranian Financial Sanctions Regulations define "foreign financial institutions" broadly to include foreign depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodities exchanges, clearing corporations, investment companies, employee benefit plans, and holding companies, affiliates, or subsidiaries of any of these entities Iran Sanctions FAQ - Office of Foreign Assets Control
Under the IFSR, the term "knowingly" means that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result Iran Sanctions FAQ - Office of Foreign Assets Control
No licensing pathway exists under Iranian law for cryptocurrency exchanges, digital asset securities issuers, custodians, or any crypto-related business because the only applicable framework in the source texts is the U.S. OFAC sanctions regime, which does not provide for licensing of crypto securities businesses in Iran Federal Register :: Iranian Transactions and Sanctions Regulations
The ITSR provides for specific licenses that may be issued with respect to the operation of Iranian accounts that constitute accounts of foreign government missions and their personnel in Iran, or diplomatic missions of the Government of Iran to international organizations in the United States or the Iranian Interests Section of the Embassy of Pakistan in the United States 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
United States depository institutions are authorized to provide limited services with respect to Iranian accounts other than blocked accounts, including maintenance of accounts, payment of interest, debiting of service charges, and closing accounts at the request of the account party who is not the Government of Iran or an Iranian financial institution 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
United States registered brokers or dealers in securities are authorized to provide limited services including maintenance of Iranian accounts other than blocked accounts, payment of interest and dividends, execution of stock splits and dividend reinvestment plans, and one-time liquidation of all assets at fair market value upon account closing 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The authorization under 31 CFR § 560.517 specifically excludes accounts of the Government of Iran, Iranian financial institutions, or any other person whose property and interests in property are blocked pursuant to § 560.211 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The general license in § 560.540 authorizes the exportation of certain services and software incident to the exchange of personal communications over the internet only where such services and software are publicly available at no cost to the user Federal Register :: Iranian Transactions and Sanctions Regulations
General License D-2 authorizes cloud-based services and software in support of authorized software or services or of any other transaction authorized pursuant to the Regulations Federal Register :: Iranian Transactions and Sanctions Regulations
General License D-2 clarifies restrictions on the exportation of web-hosting services or domain name registration services Federal Register :: Iranian Transactions and Sanctions Regulations
No capital requirements expressed in EUR or USD are stated in the source texts for any licensing regime related to crypto or digital asset securities in Iran Iran Sanctions FAQ - Office of Foreign Assets Control
No application process or timeline for a crypto-related license in Iran is described in the provided materials because no such licensing regime exists Federal Register :: Iranian Transactions Regulations
Zero entities have been licensed by any Iranian authority for cryptocurrency or digital asset securities activity, as no such licensing framework is identified in the provided sources 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
OFAC's General License D-2 was incorporated into the ITSR by a final rule effective May 17, 2024, but this license pertains only to internet communications services and software, not to digital asset securities Federal Register :: Iranian Transactions and Sanctions Regulations
The specific licensing policy expanded under GL D-2 relates to communications-related software and services, not to securities dealing, brokerage, or crypto activities Federal Register :: Iranian Transactions and Sanctions Regulations
There is no evidence in the source texts of any structural requirements imposed by an Iranian authority for digital asset securities businesses Iran Sanctions FAQ - Office of Foreign Assets Control
The source texts do not describe any AML/KYC requirements imposed by Iranian authorities for cryptocurrency or digital asset securities businesses, and no Iranian anti-money laundering rules for virtual assets are mentioned 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
OFAC's Iranian Financial Sanctions Regulations include provisions related to money laundering as a sanctionable activity for foreign financial institutions, specifically identifying "engaging in money laundering, or facilitating efforts by the Central Bank of Iran or any other Iranian financial institution" as a sanctionable activity Iran Sanctions FAQ - Office of Foreign Assets Control
The term "knowingly" under the IFSR requires that a person has actual knowledge or should have known of specific conduct, a circumstance, or a result, which is relevant for AML compliance determinations Iran Sanctions FAQ - Office of Foreign Assets Control
U.S. financial institutions are required to block all property and interests in property of the Government of Iran, including the Central Bank of Iran, and all Iranian financial institutions that are in the United States, come within the United States, or come within the possession or control of U.S. persons Iran Sanctions FAQ - Office of Foreign Assets Control
The blocking requirement means that entities appearing with the IRAN tag on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) must have their transactions blocked unless exempt or authorized by OFAC Iran Sanctions FAQ - Office of Foreign Assets Control
E.O. 13599 defines an "Iranian financial institution" as a financial institution organized under the laws of Iran or any jurisdiction within Iran, any financial institution in Iran, any financial institution wherever located owned or controlled by the Government of Iran, and any financial institution owned or controlled by any of the aforementioned entities Iran Sanctions FAQ - Office of Foreign Assets Control
An account with a W-8 form showing an address in Iran should be considered restricted unless the financial institution can prove to its satisfaction that the account holder is not in Iran Iran Sanctions FAQ - Office of Foreign Assets Control
The IFSR specifies that in determining whether a transaction is "significant," the Treasury Department may consider the size, number, frequency, and nature of the transaction, the level of awareness of management, the nexus with blocked entities, the impact on CISADA goals, whether deceptive practices are involved, and other factors Iran Sanctions FAQ - Office of Foreign Assets Control
A finding by the Treasury Department that a foreign financial institution knowingly engages in sanctionable activities is necessary before the Treasury Department can prohibit or impose strict conditions on correspondent accounts or payable-through accounts Iran Sanctions FAQ - Office of Foreign Assets Control
If the Treasury Department imposes strict conditions or prohibitions, it will issue an order or regulation published in the Federal Register or add the institution to the part 561 list Iran Sanctions FAQ - Office of Foreign Assets Control
No customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership, or PEP screening requirements from Iranian authorities are described in the provided source materials Iran Sanctions FAQ - Office of Foreign Assets Control
The source texts describe potential penalties under the IFSR, noting that any U.S. person who violates the correspondent account provisions may be subject to civil penalties of up to the greater of $250,000 or twice the transaction value, and criminal penalties for willful violations of up to $1 million and 20 years in prison Iran Sanctions FAQ - Office of Foreign Assets Control
A U.S. financial institution may be subject to civil penalties of up to the greater of $250,000 or twice the transaction value if any person it owns or controls violates the IFSR prohibition on engaging in any transaction with or benefitting the Islamic Revolutionary Guard Corps (IRGC) or its blocked affiliates, and if the U.S. financial institution knew or should have known of the violation Iran Sanctions FAQ - Office of Foreign Assets Control
The source texts do not describe any specific enforcement cases, fines, arrests, or penalties imposed on any entity for cryptocurrency or digital asset securities violations involving Iran Federal Register :: Iranian Transactions and Sanctions Regulations
No enforcement actions against named entities related to crypto and Iran are contained in the provided materials Federal Register :: Iranian Transactions Regulations
The IFSR provides that sanctions against foreign financial institutions may be waived if the Secretary of the Treasury determines that a waiver is necessary to the national interest of the United States Iran Sanctions FAQ - Office of Foreign Assets Control
The SDN List is described as dynamic, and designated persons include natural and legal persons; all interests in property of designated persons are blocked, including entities in which designated persons own a 50 percent or greater interest Iran Sanctions FAQ - Office of Foreign Assets Control
No tax guidance has been issued for virtual assets in the context of Iran, as the provided source texts do not address any taxation of cryptocurrency, digital asset securities, capital gains, income tax, or VAT with respect to Iran Iran Sanctions FAQ - Office of Foreign Assets Control
The source materials exclusively relate to U.S. economic sanctions administered by OFAC and do not contain any Iranian tax law provisions applicable to crypto or digital assets Federal Register :: Iranian Transactions and Sanctions Regulations
No Iranian tax authority, tax code, or fiscal regulation regarding virtual assets is mentioned in any of the provided source texts Federal Register :: Iranian Transactions Regulations
The ITSR provisions address export controls and financial sanctions, not tax treatment of digital assets 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
There is a complete absence of any Iranian domestic legal framework for cryptocurrency or digital asset securities, and the only applicable rules in the provided sources are U.S. sanctions regulations Federal Register :: Iranian Transactions and Sanctions Regulations
The most significant gap is that no Iranian regulatory authority has been identified as responsible for overseeing, licensing, or supervising digital asset securities activity Iran Sanctions FAQ - Office of Foreign Assets Control
Businesses engaging in any crypto or digital asset securities activity with Iranian nexus face the risk of U.S. sanctions enforcement, including civil penalties of up to the greater of $250,000 or twice the transaction value, and criminal penalties of up to $1 million and 20 years in prison for willful violations Iran Sanctions FAQ - Office of Foreign Assets Control
Foreign financial institutions that facilitate significant transactions for the Islamic Revolutionary Guard Corps or blocked Iranian-linked financial institutions may be subject to prohibition or strict conditions on their U.S. correspondent accounts or payable-through accounts Iran Sanctions FAQ - Office of Foreign Assets Control
The risk of inadvertently engaging with blocked persons is heightened because OFAC considers a person to have an interest in all property and entities in which they own, directly or indirectly, a 50 percent or greater interest, even if those entities do not appear on the SDN List Iran Sanctions FAQ - Office of Foreign Assets Control
U.S. persons, including U.S. financial institutions and securities brokers or dealers, cannot provide services related to Iranian accounts linked to the Government of Iran, Iranian financial institutions, or blocked persons under § 560.517 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The restrictions on Iranian accounts mean that even routine securities maintenance activities, such as collecting dividends, executing stock splits, or liquidating positions, are limited to non-blocked accounts and cannot involve Government of Iran entities or Iranian financial institutions 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The U-Turn payment prohibition means that no fund routing through U.S. financial institutions for Iran-related transactions is permitted, which may affect crypto-to-fiat conversions Iran Sanctions FAQ - Office of Foreign Assets Control
The W-8 address indicator rule creates compliance risk for financial institutions, as an account showing an Iranian address must be restricted unless the institution can affirmatively prove the account holder is not in Iran Iran Sanctions FAQ - Office of Foreign Assets Control
The gap between the authorization for personal communications software and services under GL D-2 and any potential crypto activity is substantial, as GL D-2 explicitly covers social media, collaboration platforms, video conferencing, e-gaming, e-learning, automated translation, web maps, and user authentication services but does not mention digital assets or securities Federal Register :: Iranian Transactions and Sanctions Regulations
The practical reality is that no crypto securities business can operate in Iran with legal certainty, as there is no Iranian licensing authority, no registration mechanism, and no compliance pathway described in the available sources 31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
The blocking requirements under E.O. 13599 create significant operational risk for any financial institution that may encounter Iranian-linked digital asset transactions, since all property of the Government of Iran, the Central Bank of Iran, and Iranian financial institutions must be frozen Iran Sanctions FAQ - Office of Foreign Assets Control
Iran Sanctions FAQ - Office of Foreign Assets Control
Federal Register :: Iranian Transactions and Sanctions Regulations
Federal Register :: Iranian Transactions Regulations
31 CFR § 560.517 - Exportation of services: Iranian accounts at United States depository institutions or United States registered brokers or dealers in securities. | Electronic Code of Federal Regulations (e-CFR) | US Law | LII / Legal Information Institute
Sanctions & Restrictions
Controlling the flow of capital and preventing money laundering/terrorist financing.
Utilizing cryptocurrencies (specifically mined ones) for import payments to circumvent sanctions.
Prohibiting or heavily restricting the domestic use and trading of cryptocurrencies by individuals and unlicensed entities.
No explicit license requirements for third-party digital asset custody services exist. This is primarily because such services are generally not permitted or recognized within a regulated framework for individual or institutional clients.
The Central Bank of Iran (CBI) has historically taken a prohibitive stance on cryptocurrency activities that could lead to capital flight or undermine the national currency. While mining has been licensed for specific purposes (see "Pending Legislation" below), this doesn't extend to general custody services.
Financial institutions (banks, credit institutions) in Iran are generally prohibited from dealing in cryptocurrencies, which would include offering custody services.
Non-existent. As there are no recognized licensed custodians, there are no rules mandating the segregation of client assets from proprietary assets.
Non-existent. Without a regulatory framework for custody services, there are no requirements for insurance or bonding.
No specific regulatory mandates. While any entity holding significant amounts of cryptocurrency (e.g., licensed miners before selling to the CBI or authorized banks) would likely use best practices like cold storage for security, this is not a regulatory mandate for a "custody service."
No definition of "qualified custodian" exists within Iranian law or regulation concerning digital assets.
Central Bank of Iran (CBI) Stance: The CBI has generally prohibited banks and financial institutions from dealing in cryptocurrencies.
Reference (Indirect): Reports often cite CBI directives. For example, a 2018 directive banned banks and financial institutions from crypto activities, which was later somewhat softened for mining but not for general trading or services.
Example News Report referencing CBI stance: "Iran Allows Banks, Exchange Bureaus to Pay for Imports With Crypto," Reuters (August 2022) - While this mentions banks paying with crypto, it's specific to imports and doesn't imply general crypto services. https://www.reuters.com/markets/currencies/iran-allows-banks-exchange-bureaus-pay-imports-with-crypto-2022-08-28/
FATF Grey List: Iran remains on the FATF's "High-Risk Jurisdictions Subject to a Call for Action" list. This significantly hinders any attempt to integrate with the global financial system and makes it extremely difficult for any entity in Iran to offer internationally compliant crypto financial services, including custody.
Reference: Financial Action Task Force (FATF) list of High-Risk Jurisdictions.
Legalization of Crypto for Imports: In 2022, Iran officially approved the use of cryptocurrencies for international trade payments, specifically imports. This framework allows miners to sell their crypto directly to the CBI or authorized banks to facilitate import payments. While this involves entities holding and managing crypto, it is a very specific use case for state-approved transactions, not general third-party custody.
Reference (News): "Iran approves using cryptocurrency for imports," Mehr News Agency (August 2022).
Reference (News): "Iran makes first official import using cryptocurrency," Tasnim News Agency (August 2022).
Mining Regulations: Iran has licensed cryptocurrency mining operations, with specific requirements for registration, energy consumption, and often mandates for selling mined crypto to the government or authorized channels. This is the most regulated aspect of the crypto industry in Iran.
Reference (News): "Iran's Central Bank, Industry Ministry to Regulate Crypto Mining," Financial Tribune (December 2020).
National Digital Currency (CBDC): The CBI has been working on a national digital currency (digital rial). This initiative is about central bank-issued digital currency, not private digital assets or third-party custody.
Central Bank of Iran (CBI) Stance: The CBI has generally prohibited banks and financial institutions from dealing in cryptocurrencies.
Money and Credit Council (MCC): A high-level policy-making body under the CBI, which has issued critical directives regarding virtual assets.
Cabinet of Ministers: Has issued resolutions governing the use of cryptocurrencies, especially for trade.
Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Supreme Council: Relevant for AML compliance, although Iran remains on the FATF's "black list" for failing to address strategic deficiencies in its AML/CFT regime.
Ministry of Industry, Mine and Trade: Involved in licensing cryptocurrency mining operations.
Retail Trading: Direct retail trading of cryptocurrencies for the general public on independent, regulated exchanges remains ambiguous and highly restricted. While some local platforms operate, their legal status for direct fiat-to-crypto and crypto-to-fiat transactions is precarious and not clearly licensed by a comprehensive framework similar to other jurisdictions.
State-Sanctioned Trading: The primary regulatory focus for exchanges is related to facilitating import payments.
In August 2022, Iran announced it had made its first official import order using cryptocurrency. This followed a 2020 Cabinet resolution that authorized the CBI to develop a mechanism for using cryptocurrencies for import payments.
Under this framework, licensed miners (see below) are allowed to sell their mined cryptocurrencies directly to the CBI or other approved entities to finance imports.
Only CBI-approved banks and licensed money exchangers are permitted to use cryptocurrencies for import and export settlements.
Key Requirement: Any entity facilitating such transactions would need explicit authorization/licensing from the CBI and likely other government bodies, aligning strictly with national economic policy.
There is no separate, explicit licensing regime for independent cryptocurrency custody providers.
Custody functions, if they exist, would be an integral part of any CBI-approved entity permitted to handle cryptocurrencies for import/export purposes. These entities would be subject to the same stringent controls and would not be offering general custodial services to the public.
Similarly, there is no independent licensing framework for general cryptocurrency payment processors.
The use of cryptocurrencies as a means of payment within Iran for goods and services is generally prohibited for the public.
The only authorized use of cryptocurrencies as a "payment" mechanism is for international trade settlement, specifically for imports, as facilitated by CBI-approved financial institutions and licensed miners. Any entity involved in this would fall under the existing financial regulations and require specific CBI authorization.
This is the most regulated and encouraged virtual asset activity in Iran due to its energy surpluses and the ability to generate hard currency for import financing.
Required License: Mining farms must obtain a license from the Ministry of Industry, Mine and Trade. They must also register with the CBI.
Miners must comply with specific electricity tariffs.
They are obliged to sell their mined cryptocurrencies directly to the CBI or other authorized financial institutions to finance imports.
Failure to obtain a license or comply with regulations can result in heavy fines, equipment confiscation, and electricity disconnections.
Capital Requirements: Substantial, though often less critical than strategic alignment.
AML/KYC Requirements: Extremely stringent under Iranian law, despite international concerns about Iran's overall AML/CFT regime (due to FATF blacklisting). Any licensed entity would be expected to implement robust customer identification, transaction monitoring, and suspicious activity reporting within the Iranian legal framework.
Local Presence: Absolutely mandatory. Full operational presence in Iran is a prerequisite.
Alignment with National Interests: A critical, unwritten requirement. The activity must directly serve the state's economic goals (e.g., import financing, sanctions circumvention).
Security and Data Localization: Strict requirements for cybersecurity, data storage, and potentially data localization within Iran.
Reporting: Extensive and frequent reporting to the CBI and other relevant authorities.
Opaque and Centralized: Involving multiple government ministries and agencies.
Lengthy and Complex: Requiring extensive documentation and background checks.
Politically Sensitive: Success often hinges on demonstrating how the proposed activity serves Iran's national economic and strategic interests.
Direct Application: Likely to the CBI for financial aspects, and the Ministry of Industry, Mine and Trade for mining.
CBI & Money and Credit Council (MCC) Resolution on Virtual Currencies (2018/2019): This initial directive banned the use of cryptocurrencies as legal tender and for payments within Iran but allowed mining under specific conditions.
Reference: Often cited in news articles, e.g., Reuters, Financial Times. Direct CBI link usually in Farsi.
CBI Official Website (Farsi): https://www.cbi.ir/ - Navigating this for specific decrees requires Farsi proficiency.
Cabinet of Ministers Resolution on Crypto Mining for Import Financing (2020): This authorized the CBI and Ministry of Industry, Mine and Trade to issue regulations for miners to sell their output to finance imports.
Reference: Reported by numerous news outlets.
Official Iranian Government Portal (Farsi): https://www.irangov.ir/ - Decrees are published here but are in Farsi.
Ministry of Industry, Mine and Trade: Involved in licensing cryptocurrency mining operations.
FATF Statement on Iran: Crucial context for any financial activity involving Iran. Iran is on the FATF's "High-Risk Jurisdictions Subject to a Call for Action" list.
Search for "Iran" in their "High-Risk Jurisdictions" section.
Sanctioned individuals or entities: Any person or organization listed on relevant sanctions lists.
Prohibited jurisdictions: Transactions directly involving Iran.
Prohibited activities: Certain types of trade, financing, or services involving Iran.
Iranian Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560: These regulations implement various Executive Orders imposing sanctions on Iran. They generally prohibit U.S. persons from engaging in virtually any transaction with Iran, its government, or persons ordinarily resident in Iran.
Legal Reference: 31 CFR Part 560 (Available via ECFR: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560)
Executive Orders (EOs): Numerous EOs underpin the Iran sanctions program, including:
EO 13599 (2012): Blocking Property of the Government of Iran and Iranian Financial Institutions.
EO 13876 (2019): Imposing Sanctions with Respect to Iran.
OFAC Sanctions Program - Iran: Provides an overview of current EOs and regulations.
Legal Reference: OFAC Iran Sanctions Program: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/iran-sanctions
OFAC has explicitly clarified that its sanctions programs apply to transactions involving virtual currency just as they do to traditional fiat currency.
Legal Reference: OFAC's "A Framework for OFAC Compliance Commitments" (2019), Appendix A (FAQs on Virtual Currency): https://home.treasury.gov/system/files/126/sanc_compliance_framework_factsheet.pdf (See Virtual Currency-Related Sanctions Risks)
Legal Reference: OFAC Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (2020), which reiterates that virtual currency companies must comply with OFAC regulations: https://home.treasury.gov/system/files/126/ofac_ransomware_advisory_10012020_1.pdf
SDN List: VASPs must screen all their customers, counterparties, and relevant transaction parties against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List. This includes individuals, entities, and sometimes their associated virtual currency addresses.
Legal Reference: OFAC SDN List: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-list-search
50 Percent Rule: VASPs must also block property and interests in property of entities that are owned 50 percent or more, directly or indirectly, by one or more blocked persons, even if those entities are not explicitly listed on the SDN List.
Legal Reference: OFAC 50 Percent Rule: https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list/the-50-percent-rule
All transactions involving Iran are generally prohibited for U.S. persons. For non-U.S. VASPs, secondary sanctions can apply if they engage in significant transactions with the Government of Iran or designated entities (e.g., related to the IRGC, oil, or financial institutions).
Council Regulations: The core legal instruments for EU sanctions are Council Regulations, which are directly applicable in all EU Member States. Key regulations include:
Council Regulation (EU) No 267/2012: Concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010 (Nuclear proliferation).
Council Decision (CFSP) 2011/235/CFSP: Concerning restrictive measures directed against certain persons and entities in view of the situation in Iran (Human rights).
Council Regulation (EU) 2023/1529: Concerning restrictive measures against Iran (Terrorism financing and support).
Legal Reference: EEAS - Iran Sanctions Map: https://www.sanctionsmap.eu/#/main (Filter for Iran)
Legal Reference: EUR-Lex (official journal for EU legislation): https://eur-lex.europa.eu/ (Search for relevant Council Regulations and Decisions)
While explicit regulations on "crypto sanctions" against Iran are rare, the EU's asset freeze and financial transfer restrictions extend to virtual assets under the general definition of "funds" or "economic resources."
The EU's recent MiCA (Markets in Crypto-Assets) regulation includes provisions for AML/CFT and compliance with sanctions, making it clear VASPs must adhere to existing sanctions regimes.
EU Consolidated Financial Sanctions List: VASPs operating in the EU must screen against the EU's consolidated list of persons, groups, and entities subject to financial sanctions.
Legal Reference: EU Financial Sanctions Database: https://sanctions.plana.info/ (This is a public database by the EU Commission)
National Lists: Member States may also maintain their own lists in addition to the EU list.
EU persons (citizens, entities incorporated in an EU Member State, or persons operating in the EU) are prohibited from making funds or economic resources available, directly or indirectly, to designated Iranian individuals or entities.
UNSCR 2231 (2015): Endorsed the JCPOA and lifted many previous nuclear-related sanctions, but maintained some restrictions related to ballistic missiles and conventional arms transfers (some of which have since expired or been subject to US snapback claims).
Legal Reference: UNSCR 2231 (2015): https://undocs.org/S/RES/2231(2015))
Terrorism Sanctions: Iran is also subject to UN sanctions if any of its entities or individuals are designated under the UN's global terrorism sanctions regimes (e.g., related to ISIL (Da'esh) and Al-Qaida, or others). These designations are separate from Iran-specific nuclear sanctions.
Legal Reference: UN Security Council Sanctions Committees (e.g., Al-Qaida Sanctions Committee): https://www.un.org/securitycouncil/sanctions/information
Any financial transaction with an entity or individual designated on a UN sanctions list (e.g., for terrorism) involving virtual assets would be a violation of UN sanctions, which are binding on all UN Member States.
UN Consolidated Sanctions List: VASPs must screen against the UN Security Council Consolidated List, which includes individuals and entities subject to various UN sanctions regimes.
Legal Reference: UN Security Council Sanctions Committees (e.g., Al-Qaida Sanctions Committee): https://www.un.org/securitycouncil/sanctions/information
Identify and verify the identity of customers and beneficial owners.
Assess the risk profile of customers, including their geographic location and any links to sanctioned jurisdictions like Iran.
Automated Screening: Implement systems to screen all new and existing customers, as well as transaction counterparties, against all relevant national, EU, UN, and OFAC sanctions lists (SDN, EU CFSP, UN Consolidated List).
Continuous Monitoring: Regularly re-screen customers and monitor transactions for potential sanctions breaches.
Implement technical controls (e.g., IP address blocking) to prevent access to services from Iran or from entities known to operate within Iran.
Be aware of VPN usage and other methods used to circumvent geo-restrictions.
Monitor transaction patterns for unusual activity, large transfers to/from high-risk jurisdictions, or attempts to obfuscate beneficial ownership.
Look for direct or indirect connections to Iranian IP addresses or known Iranian entities.
Blocking: Immediately freeze/block any virtual assets or accounts belonging to sanctioned individuals or entities. Do not process transactions.
Reporting: Report blocked property and suspicious transactions (SARs/STRs) to the relevant authorities (e.g., OFAC for U.S. persons, national FIUs for EU VASPs).
FATF Recommendations: The Financial Action Task Force (FATF) recommends that VASPs implement measures to prevent the misuse of virtual assets for proliferation financing (PF) and terrorism financing (TF), which includes adherence to targeted financial sanctions.
Legal Reference: FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (2021): https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Virtual-Assets-RBA-2021.pdf (See Recommendation 6 on targeted financial sanctions related to proliferation and terrorism).
FATF Recommendation 15 (New Technologies): Requires countries and VASPs to identify and assess risks, and apply AML/CFT measures to virtual assets.
Civil Penalties: Can range from thousands to millions of dollars per violation, depending on the severity and number of transactions. OFAC often calculates penalties based on the value of the transaction.
Example: OFAC has imposed significant fines on crypto companies for violations, including Bittrex ($24 million), BitGo ($99,828), and Kraken ($362,158) for allowing customers in sanctioned jurisdictions (including Iran) to transact.
Legal Reference: OFAC Recent Enforcement Actions: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions
Criminal Penalties: For willful violations, individuals can face substantial fines and imprisonment (up to 20 years), and corporations can face fines in the millions.
Penalties for sanctions violations are determined by individual EU Member States. They typically include significant fines, asset freezes, and imprisonment for individuals found guilty of violating sanctions laws.
Beyond financial and criminal penalties, non-compliance can lead to severe reputational damage, loss of trust, and potential blacklisting from traditional financial services.
OFAC SDN List: Includes numerous individuals and entities based in Iran or acting on behalf of the Iranian government, IRGC, or other designated organizations. These designations apply to all forms of assets, including virtual currencies.
Specific Crypto Designations (General): While not Iran-specific, OFAC has designated virtual currency addresses and entities involved in sanctions evasion (e.g., for North Korea) or other illicit activities. If Iranian actors were found to be using these designated addresses, transactions with them would also be prohibited.
Legal Reference: OFAC's List of Digital Currency Addresses: https://home.treasury.gov/policy-issues/financial-sanctions/special-designated-nationals-and-blocked-persons-list-sdn-human-readable-list#add (Scroll down to "List of Digital Currency Addresses")
EU Consolidated Financial Sanctions List: VASPs operating in the EU must screen against the EU's consolidated list of persons, groups, and entities subject to financial sanctions.
UN Consolidated Sanctions List: Lists entities and individuals sanctioned by the UN, which would include any Iranian entities designated under terrorism or other applicable regimes.
Enforcement Actions
Tavanir (Iran Electricity Generation, Transmission and Distribution Company): The primary entity responsible for identifying and disconnecting illegal mining operations.
Law Enforcement Force (LEF): Conducts raids and arrests.
Iran's judiciary is used as a political tool to prosecute and repress peaceful protesters, political opponents, and individuals deemed security threats, often under post-war security laws, as documented by EU sanctions and human rights monitors.
Ministry of Energy: Sets policies and oversees Tavanir.
Entities Targeted: Unlicensed cryptocurrency mining farms, both large-scale industrial operations and smaller home-based setups.
Illicit cryptocurrency mining without a license.
Electricity theft or misuse of subsidized electricity.
Operating energy-intensive equipment without authorization.
Confiscation of equipment: Thousands of mining rigs (ASICs) have been confiscated, valued at millions of dollars collectively. For example, in June 2021, Tavanir announced the confiscation of 7,000 illicit mining machines.
Fines: Imposed based on the amount of electricity consumed and potential damages. Specific individual amounts are rarely disclosed but can be substantial.
Disconnection from Power Grid: Mandatory for detected illegal operations.
Arrests and Imprisonment: Individuals operating these farms often face arrest, fines, and potential prison sentences. Reports frequently mention dozens or hundreds of arrests during major campaigns.
Dates: This has been an ongoing, continuous campaign, with intensified periods coinciding with peak electricity demand (e.g., hot summers, cold winters).
June 2021: Tavanir announced the shutdown of 6,914 illegal mining farms and confiscation of 200,000 mining devices since March 2021.
December 2022 - January 2023: Renewed crackdowns amid severe winter energy shortages.
Summer 2023: Continued confiscations and arrests were reported to combat energy drain.
Tens of thousands of illegal mining machines seized.
Temporary relief on the power grid during crackdowns, though the problem tends to resurface due to economic incentives.
Increased regulatory pressure for licensed mining operations to adhere strictly to rules and pay commercial electricity rates.
Reuters: Iran confiscates 7,000 illegal crypto mining machines as power cuts worsen
Bloomberg: Iran’s Power Chief Says 200,000 Crypto Devices Seized
Tehran Times (via IRNA): Over 117,000 unauthorized cryptocurrency mining devices seized in Iran (Reports on ongoing seizures into 2023)
Regulator Name: Central Bank of Iran (CBI)
Unlicensed cryptocurrency exchanges operating within Iran.
Individuals engaging in unauthorized buying/selling of cryptocurrencies.
Banks and credit institutions attempting to deal in cryptocurrencies without explicit CBI approval.
Operating a cryptocurrency exchange without a valid license from the CBI or other designated authority.
Facilitating foreign exchange transactions using cryptocurrency without authorization.
Money laundering and financing of terrorism (often cited as underlying risks of unauthorized activities).
Violation of foreign exchange regulations.
Warnings and service disruptions: Unlicensed platforms face the risk of being blocked or shut down.
Financial penalties: While specific amounts against individual exchanges are not widely reported, non-compliance can lead to severe fines and legal action under existing banking and anti-money laundering laws.
Confiscation of funds: Possible if illicit transactions are proven.
Dates: Ongoing, with key regulatory pronouncements and reiterations.
April 2021: CBI reiterates its ban on domestic crypto trading by banks and financial institutions, though it later clarified the use of mined crypto for import payments.
Late 2022 - Early 2023: Continued warnings against unauthorized platforms amidst increasing public interest in crypto.
Creates a highly restricted environment for crypto trading in Iran, pushing much of the activity underground or to international platforms (which can be risky for users).
Forces exchanges to seek specific licenses, if available, or cease operations.
The CBI aims to control capital outflow and prevent the use of crypto for purposes contrary to national economic policy.
Al Jazeera: Iran bans cryptocurrency trading by banks, financial institutions
Financial Tribune (English-language Iranian newspaper): CBI Urges Public to Avoid Unlicensed Crypto Exchange (Reports in late 2023 on continued warnings)
Atlantic Council: Iran's shifting stance on cryptocurrency and blockchain (Provides context on regulatory shifts, including CBI's role)
Transparency: Iranian authorities are not highly transparent with detailed enforcement statistics, particularly concerning specific financial penalties or individual company actions.
Focus on Mining: The overwhelming majority of detailed enforcement reports from Iran concern illegal cryptocurrency mining, largely due to its visible and immediate impact on the national power grid.
Sanctions: Iran's use of crypto for sanctions evasion is a significant international concern, but internal enforcement actions generally target domestic illicit activities, not necessarily the use of crypto for state-sanctioned international transactions.
Research & Articles
Regulatory Forecast
high confidenceLikely enforcement action expected around 2026-08-21
Based on 160 historical regulatory events for Iran, averaging every 89 days, with increasing regulatory activity.
Recent Updates
Basis: UN Security Council Resolutions are legally binding on all UN member states, including Côte d'Ivoire. Thes...
Basis: UN Security Council Resolutions are legally binding on all UN member states, including Côte d'Ivoire. These resolutions typically impose asset freezes, travel bans, and arms embargoes on individuals, entities, and countries deemed threats to international peace and security (e.g., related to terrorism, proliferation of weapons of mass destruction, specific regimes like North Korea or Iran).
International Sanctions: Iran is under extensive international sanctions (primarily from the US), which prohibit ...
International Sanctions: Iran is under extensive international sanctions (primarily from the US), which prohibit most financial transactions involving Iranian entities or individuals, further complicating VASP operations.
Evolving Domestic Stance: Iran's stance on cryptocurrencies has evolved from outright bans to allowing regulated ...
Evolving Domestic Stance: Iran's stance on cryptocurrencies has evolved from outright bans to allowing regulated mining and exploring the use of crypto for bypassing sanctions (e.g., import payments), while generally maintaining strict controls over public trading and use for domestic payments.
No General Retail VASP Market: There is no established, government-sanctioned, retail-facing VASP market (like op...
No General Retail VASP Market: There is no established, government-sanctioned, retail-facing VASP market (like open crypto exchanges) for the general public in Iran due to the general ban on crypto for payments and significant restrictions on trading.
International Isolation: Due to FATF blacklisting and international sanctions, it is virtually impossible for any...
International Isolation: Due to FATF blacklisting and international sanctions, it is virtually impossible for any reputable international VASP to legally offer services to Iranian citizens or entities, regardless of Iran's domestic regulations. Doing so would expose them to severe regulatory and reputational risks.
The Central Bank of Iran (CBI) has historically taken a prohibitive stance on cryptocurrency activities that could le...
The Central Bank of Iran (CBI) has historically taken a prohibitive stance on cryptocurrency activities that could lead to capital flight or undermine the national currency. While mining has been licensed for specific purposes (see "Pending Legislation" below), this doesn't extend to general custody services.
Financial institutions (banks, credit institutions) in Iran are generally prohibited from dealing in cryptocurrencies...
Financial institutions (banks, credit institutions) in Iran are generally prohibited from dealing in cryptocurrencies, which would include offering custody services.
Non-existent. Without a regulatory framework for custody services, there are no requirements for insurance or bon...
Non-existent. Without a regulatory framework for custody services, there are no requirements for insurance or bonding.
No specific regulatory mandates. While any entity holding significant amounts of cryptocurrency (e.g., licensed m...
No specific regulatory mandates. While any entity holding significant amounts of cryptocurrency (e.g., licensed miners before selling to the CBI or authorized banks) would likely use best practices like cold storage for security, this is not a regulatory mandate for a "custody service."
Central Bank of Iran (CBI) Stance: The CBI has generally prohibited banks and financial institutions from dealing...
Central Bank of Iran (CBI) Stance: The CBI has generally prohibited banks and financial institutions from dealing in cryptocurrencies.
Legalization of Crypto for Imports: In 2022, Iran officially approved the use of cryptocurrencies for internation...
Legalization of Crypto for Imports: In 2022, Iran officially approved the use of cryptocurrencies for international trade payments, specifically imports. This framework allows miners to sell their crypto directly to the CBI or authorized banks to facilitate import payments. While this involves entities holding and managing crypto, it is a very specific use case for state-approved transactions, not general third-party custody.
National Digital Currency (CBDC): The CBI has been working on a national digital currency (digital rial). This in...
National Digital Currency (CBDC): The CBI has been working on a national digital currency (digital rial). This initiative is about central bank-issued digital currency, not private digital assets or third-party custody.
Regulator Name: Central Bank of Iran (CBI)
Regulator Name: Central Bank of Iran (CBI)
Focus on Mining: The overwhelming majority of detailed enforcement reports from Iran concern illegal cryptocurren...
Focus on Mining: The overwhelming majority of detailed enforcement reports from Iran concern illegal cryptocurrency mining, largely due to its visible and immediate impact on the national power grid.
Sanctions: Iran's use of crypto for sanctions evasion is a significant international concern, but internal enforc...
Sanctions: Iran's use of crypto for sanctions evasion is a significant international concern, but internal enforcement actions generally target domestic illicit activities, not necessarily the use of crypto for state-sanctioned international transactions.
There is no separate, explicit licensing regime for independent cryptocurrency custody providers.
There is no separate, explicit licensing regime for independent cryptocurrency custody providers.
Custody functions, if they exist, would be an integral part of any CBI-approved entity permitted to handle cryptocurr...
Custody functions, if they exist, would be an integral part of any CBI-approved entity permitted to handle cryptocurrencies for import/export purposes. These entities would be subject to the same stringent controls and would not be offering general custodial services to the public.
Alignment with National Interests: A critical, unwritten requirement. The activity must directly serve the state'...
Alignment with National Interests: A critical, unwritten requirement. The activity must directly serve the state's economic goals (e.g., import financing, sanctions circumvention).
Politically Sensitive: Success often hinges on demonstrating how the proposed activity serves Iran's national eco...
Politically Sensitive: Success often hinges on demonstrating how the proposed activity serves Iran's national economic and strategic interests.
Traditional Securities Law: Iran's Securities Market Law of 2005 defines "securities" generally to include shares...
Traditional Securities Law: Iran's Securities Market Law of 2005 defines "securities" generally to include shares, bonds, mutual fund units, and other instruments that grant ownership rights, debt claims, or partnership interests.
Lack of Specific Crypto Guidance: The challenge with private crypto tokens is that they haven't been explicitly b...
Lack of Specific Crypto Guidance: The challenge with private crypto tokens is that they haven't been explicitly brought under this existing framework for public offerings. The regulatory emphasis has been on banning or heavily restricting their use rather than establishing a formal classification process for investor protection in a public market context.
Implicit Interpretation (Hypothetical): If a private token were to be issued seeking public investment with an ex...
Implicit Interpretation (Hypothetical): If a private token were to be issued seeking public investment with an expectation of profit derived from the efforts of others (similar to the Howey test's criteria), it would likely face significant scrutiny and potential prohibition under existing financial regulations, rather than being formally classified and regulated as a security by the SEO. The primary concern would be capital flight, AML, and monetary stability, as opposed to investor protection in a nascent token market.
Any entity attempting to launch an Initial Coin Offering (ICO) or similar token sale to the Iranian public would like...
Any entity attempting to launch an Initial Coin Offering (ICO) or similar token sale to the Iranian public would likely face regulatory challenges, including potential bans or legal action from the CBI, given the restrictions on cryptocurrency activities by financial institutions and the general public.
General Cryptocurrency Trading: While a full ban on individuals owning or trading cryptocurrencies is difficult t...
General Cryptocurrency Trading: While a full ban on individuals owning or trading cryptocurrencies is difficult to enforce, the CBI has repeatedly warned against their use and banned financial institutions from dealing with them.
2018: The CBI officially banned Iranian banks and financial institutions from dealing in cryptocurrencies, citing...
2018: The CBI officially banned Iranian banks and financial institutions from dealing in cryptocurrencies, citing money laundering and financing of terrorism concerns.
Ongoing: Warnings issued by the CBI and law enforcement against illegal cryptocurrency exchanges and platforms th...
Ongoing: Warnings issued by the CBI and law enforcement against illegal cryptocurrency exchanges and platforms that do not adhere to AML/KYC regulations or facilitate prohibited activities. The judiciary has often highlighted the risks associated with investing in unregulated crypto schemes.
Status: Highly restricted, often considered illegal or at least strongly discouraged by the Central Bank for dome...
Status: Highly restricted, often considered illegal or at least strongly discouraged by the Central Bank for domestic speculative purposes. This makes a formal tax framework for individual gains largely moot.
Effective Date: Not applicable. Since the rule has not been adopted, there is no effective date.
Effective Date: Not applicable. Since the rule has not been adopted, there is no effective date.
Threshold Amounts: Not applicable. Without adoption, there are no defined threshold amounts for the Travel Rule.
Threshold Amounts: Not applicable. Without adoption, there are no defined threshold amounts for the Travel Rule.
Which VASPs are Covered: Not applicable. There is no regulatory framework in Iran that mandates VASPs to comp...
Which VASPs are Covered: Not applicable. There is no regulatory framework in Iran that mandates VASPs to comply with the FATF Travel Rule. Domestic regulations regarding virtual assets are primarily focused on controlling their use within the country and have not incorporated international AML/CFT standards to this extent.
FATF Blacklisting: Iran remains on the FATF's "Public Statement – High-Risk Jurisdictions Subject to a Call for A...
FATF Blacklisting: Iran remains on the FATF's "Public Statement – High-Risk Jurisdictions Subject to a Call for Action" as of February 2020, with no removal since. The FATF suspended counter-measures but urged members to apply enhanced due diligence and countermeasures due to Iran's failure to enact the Palermo and Terrorist Financing Conventions FATF Public Statement
International Sanctions: Iran is under extensive US sanctions (OFAC-administered) that prohibit most financial tr...
International Sanctions: Iran is under extensive US sanctions (OFAC-administered) that prohibit most financial transactions involving Iranian entities or individuals, severely impacting any VASP operations with Iran FinCEN/OFAC Proposed Rule
Law on Combating the Financing of Terrorism (LCFT): Enacted in 2015 and amended in 2019, addressing terrorist fin...
Law on Combating the Financing of Terrorism (LCFT): Enacted in 2015 and amended in 2019, addressing terrorist financing. Any VASP operating in Iran would be subject to its provisions regarding sanctions screening and suspicious transaction reporting CBI Official Site
Central Bank of Iran (CBI): Primary regulator for financial services and virtual assets. The CBI banned banks fro...
Central Bank of Iran (CBI): Primary regulator for financial services and virtual assets. The CBI banned banks from dealing in cryptocurrencies in April 2018, though its stance has evolved to allow licensed mining and import payments via crypto CBI Official Site
Ministry of Industry, Mines, and Trade (MIMT): Responsible for licensing cryptocurrency mining operations, issuin...
Ministry of Industry, Mines, and Trade (MIMT): Responsible for licensing cryptocurrency mining operations, issuing regulations in 2019 and subsequent amendments, treating mining as an industrial activity CBI Official Site
No General Retail VASP Market: No government-sanctioned retail-facing crypto exchanges exist for the general publ...
No General Retail VASP Market: No government-sanctioned retail-facing crypto exchanges exist for the general public due to the ban on crypto for payments and significant trading restrictions CBI Official Site
2018 CBI Ban: CBI banned banks from dealing in cryptocurrencies citing ML/TF concerns CBI Official Site
2018 CBI Ban: CBI banned banks from dealing in cryptocurrencies citing ML/TF concerns CBI Official Site
Capital Flight Enforcement: Significant movement of capital out of Iran via crypto is a major concern with string...
Capital Flight Enforcement: Significant movement of capital out of Iran via crypto is a major concern with stringent enforcement CBI Official Site
CBI Circular (April 2018): Formalized ban on banks dealing with cryptocurrencies CBI Official Site
CBI Circular (April 2018): Formalized ban on banks dealing with cryptocurrencies CBI Official Site
ICOs Face Regulatory Challenges: Any entity attempting an ICO to the Iranian public would face potential bans or ...
ICOs Face Regulatory Challenges: Any entity attempting an ICO to the Iranian public would face potential bans or legal action from CBI CBI Official Site
CBDC Development: CBI developing national digital currency ("Paymon" or "Digital Rial") for domestic payments and...
CBDC Development: CBI developing national digital currency ("Paymon" or "Digital Rial") for domestic payments and interbank settlements, not as a public investment security CBI Official Site
International Penalties (FATF): Continued presence on FATF blacklist results in severe economic sanctions, financ...
International Penalties (FATF): Continued presence on FATF blacklist results in severe economic sanctions, financial isolation, difficulty accessing global financial systems, and enhanced due diligence requirements for any entity transacting with Iranian entities FATF Public Statement
International VASPs: Virtually impossible to legally offer services to Iranian citizens/entities due to FATF blac...
International VASPs: Virtually impossible to legally offer services to Iranian citizens/entities due to FATF blacklisting and international sanctions; doing so exposes entities to severe regulatory and reputational risks FATF Public Statement
FinCEN/OFAC Stablecoin Proposed Rule
FinCEN/OFAC Stablecoin Proposed Rule
Federal Register AML/CFT Proposed Rule
Federal Register AML/CFT Proposed Rule
The application of international financial sanctions includes prohibitions or restrictions of certain financial activ...
The application of international financial sanctions includes prohibitions or restrictions of certain financial activities/services and the freeze of funds, assets, or other economic resources, targeting persons and entities associated with Al-Qaida, the Taliban, or persons cited under European regulations concerning Belarus, Iran, and other countries Source: CSSF International Financial Sanctions
This profile is maintained by AI research workers and updated regularly. Connect via MCP for programmatic access.