Iran’s internet technically stayed connected to the global network, but user activity dropped to nearly zero. This indicates a deliberate, centrally managed restriction on citizens’ access to the outside internet. Source: IODA.
Yet amid that digital blackout, one critical financial service kept running without a hitch: Nobitex, a cryptocurrency exchange with deep ties to Iran’s ruling establishment.
We gathered all available information about the platform to understand how Iranian authorities leverage it, what blockchain analytics firms have uncovered, and why — despite mounting evidence — the exchange has yet to be added to OFAC’s SDN List.
The scale and reach of Iran’s crypto powerhouse
Nobitex is no small-time operation. While exact figures differ across sources, analysts broadly agree that billions of dollars in assets flow through the exchange. TRM Labs, for example, tracked roughly $5 billion in observed volume between 2025 and March 2026.
Previously, Chainalysis reported that asset inflows to Nobitex wallets surpassed the combined total of Iran’s 10 next-largest exchanges. Source: Chainalysis.
Nobitex boasts a massive retail customer base. By the platform’s own count, it serves approximately 11 million Iranians — nearly 12% of the country’s population.
The exchange provides a full range of industry-standard services: spot and margin trading, yield-generating products, liquidity pools, digital gift cards, and even loans backed by crypto collateral.
Nobitex also caters to professional traders and institutional clients, offering them preferential terms such as higher transaction limits and high-speed API access.
What truly put the platform in the spotlight, however, wasn’t its consumer-facing business. It was evidence suggesting Nobitex serves as a national currency gateway for a country locked out of SWIFT.
A shadow banking network
Multiple investigations published online examine how Nobitex enables Iran’s leadership to circumvent economic sanctions.
In January 2026, Elliptic released a report documenting systematic USDT stablecoin purchases by Iran’s central bank. The firm found that transactions worth at least $507 million were executed through a broker based in the UAE, with the funds sent “primarily” to Nobitex.
Since those stablecoins could be converted into rials, the central bank was effectively conducting foreign exchange operations entirely outside the international banking system.
This is hardly the only way the state uses the exchange. A recent Reuters investigation traced the platform’s founders — brothers Ali and Mohammad Kharrazi — to one of Iran’s most powerful political and clerical dynasties.
The news agency also confirmed that one of the exchange’s largest early backers was Mohammad Baqer Nahvi, vice president of Safiran Airport Services — a firm added to the OFAC SDN List in September 2022 for arranging flights to deliver Iranian drones to Russia.
Separately, both Elliptic and Chainalysis have documented Nobitex’s connections to wallets tied to Hamas, the Houthi Ansar Allah movement, the Gaza Now propaganda outlet, and the sanctioned Russian exchange Garantex.
The exchange appears to have been architected from day one to function under sanctions pressure.
In June 2025, Nobitex’s source code and portions of its internal documentation were leaked online. The code reportedly included modules for generating stealth addresses, batching and splitting transactions, switching endpoints, and specific logic built to bypass compliance screening. A document titled “Nobitex Privacy” was also published, openly outlining a strategy to evade FinCEN tools and Western blockchain analytics.
Half measures or deliberate restraint?
In April 2026, reports emerged that Iranian entities were collecting cryptocurrency payments from vessel operators in exchange for safe passage through the Strait of Hormuz. Cryptocurrency has reportedly become one of the main payment methods for these arrangements.
The scheme appears to have been highly effective, suggesting digital assets will remain a go-to tool for similar operations going forward.
Given this context, placing Nobitex on the SDN List — as was done with Garantex — might seem like a natural next step, even though such flows typically don’t move through retail platforms. Yet no such action has been taken.
The U.S. Treasury Department has previously sanctioned Iran-linked cryptocurrency exchanges, but those platforms were registered in the United
Kingdom. Nobitex, on the other hand, is registered in Iran as a domestic company.
Importantly, on the same day Reuters released its investigation into Nobitex, OFAC specified that Iranian digital asset exchanges are already treated as blocked financial institutions, regardless of whether they are individually named on the SDN List.
For a platform physically located in Iran, however, this has limited practical impact: its main operations focus on Iranian users and neutral foreign intermediaries.
An SDN listing works differently. It imposes secondary sanctions against any non-U.S. counterparties worldwide, offers direct justification for bulk asset freezes by stablecoin issuers, and forces foreign exchanges and OTC desks to cut ties or risk being designated themselves.
Why an individual SDN listing may be unnecessary
The U.S. Treasury has not explained why an individual SDN listing for Nobitex has not followed. However, it is worth noting that the department has never included platforms incorporated within Iran on the list — and there are multiple such platforms.
OFAC’s approach toward Iran’s local crypto market is based on targeted measures. Three main strategies stand out:
- Sanctions against specific addresses.
- Designation of exchange houses — a recent instance being the addition of exchanges allegedly handling the state’s shadow oil revenues.
- Designation of individuals and OTC brokers.
Regarding Nobitex itself, any explanation can only be speculative. The first has already been outlined: OFAC uses a different approach toward local Iranian platforms, and Nobitex simply fits within that logic rather than outside it.
The U.S. Treasury may also consider such measures unnecessary. As previously noted, U.S. persons are already prohibited from transacting with Iranian exchanges; from the standpoint of formal access, an individual listing adds little to existing restrictions.
There is also the “human shield” hypothesis. Speaking to Reuters, Nick Smart, Chief Intelligence Officer at Crystal Intelligence, observed that the platform hosts a high concentration of activity from ordinary Iranians. He suggested that separating the regime from the citizens using the exchange is nearly impossible, as their assets are commingled.
In this context, the Garantex case appears to be the opposite scenario: the platform operated as a B2B hub for shadow capital. That made it possible to physically seize its servers without causing social damage to retail users.
There is no direct public confirmation that this is the logic holding OFAC back.
Finally, a strike against Nobitex may be seen as less effective without a simultaneous move against external “exits.” The value of sanctions arises not at the “entry point,” but where funds leave the country: foreign exchanges, stablecoin issuers, OTC brokers, banks, and other intermediaries.
The double-edged sword
The Nobitex case is another reminder that the mass adoption the industry dreams of is a double-edged sword.
On one hand, the exchange gives Iranians cut off from the world a measure of financial freedom: a way to shield savings from rial inflation and retain at least some access to dollar liquidity. On the other, the state uses the same infrastructure for its own purposes, ranging from central bank currency interventions to transfers to regional proxies.
The key point is that this is no longer an isolated practice. Chainalysis ranks Iran alongside Russia and North Korea, noting that for all three states, “what were once experimental and opportunistic tactics have matured into institutionalized strategies embedded within national economic and security policy.”
The Iranian model — a mass retail platform based in an unreachable territory coupled with offshore proxy structures — looks like a working template. Future sanctioned regimes will likely look to this experience.
That raises a reverse question — this time for regulators themselves.
What is the acceptable cost of sanctions pressure when the regime’s funds and the savings of millions of ordinary users are physically commingled on a single platform? Can the assets of 11 million people be frozen to cut off the state’s financial channel — or is that precisely the line the SDN mechanism, in its current form, does not cross?
OFAC has yet to provide a public answer, and the Nobitex case only sharpens the debate.
