The Internet in Iran formally remained part of global routing, but user activity dropped to almost zero. This indicates a managed restriction of citizens’ access to the external network. Source: IOD.
But in this digital darkness, one vital financial service continued to operate without interruption: Nobitex, a cryptocurrency exchange connected to Iran’s ruling elite.
We collected available information about the platform and tried to understand how Iranian authorities are using it, what investigations by analyst firms have revealed and why, despite all these findings, the exchange is still not on OFAC’s SDN list.
The scale and scope of the Iranian crypto giant
Nobitex is not a niche platform. While estimates vary, analysts agree that asset flows passing through the exchange are measured in the billions of dollars. For example TRM Labs recorded the observed volume is approximately $5 billion between 2025 and March 2026.
Earlier, Chainalytic noted that the inflow of assets to Nobitex addresses exceeded the total of the other 10 largest exchanges in Iran. Source: Chain analysis.
Nobitex has a wide base of retail users. According to the platform own figuresserves approximately 11 million Iranians, or almost 12% of the country’s population.
The exchange offers a suite of services typical of the industry: spot and margin trading, profit-generating products, liquidity pools, digital gift cards and even cryptocurrency-backed loans.
Nobitex also serves professional market participants and institutional players. These entities are there provided that with specialized terms such as increased limits and brisk APIs.
What caught the platform’s attention, however, was not its retail business. This was information suggesting that Nobitex was acting as a national currency gateway for a country cut off from SWIFT.
Parallel banking network
A number of investigations available online focus on how Nobitex helps Iranian leaders avoid economic sanctions.
In January 2026, Elliptical published the report detailing systematic purchases of the USDT stablecoin by the Iranian central bank. According to the company, transactions totaling at least $507 million were conducted through a broker in the United Arab Emirates, with assets transferred “primarily” to Nobitex.
Because stablecoins could be sold for rials, the regulator effectively conducted currency intervention outside the international banking system.
This is not the only case of the state using exchange. Recent Reuters investigation linked the founders of the platform – brothers Ali and Mohammad Kharrazi – with one of the most influential political and clerical families in the country.
The agency also found that one of the largest early investors on the stock exchange was Mohammad Baqer Nahvi, vice president of Safiran Airport Services – a company placed in September 2022 on the OFAC SDN list for organizing flights to deliver Iranian drones to Russia.
Separately, Elliptical AND Chain analysis documented Nobitex’s ties to wallets linked to Hamas, the Houthi Ansar Allah movement, the Gaza Now propaganda website and the sanctioned Russian stock exchange Garantex.
The exchange itself appears to have built its infrastructure from the beginning with sanctioned activity in mind.
In June 2025, the source code of the platform and fragments of its internal documentation were made available leaked on the Internet. According to this data, the code contained modules for generating hidden addresses, grouping and splitting transactions, switching endpoints, and special logic designed to bypass compliance checks. A document titled “Nobitex Privacy” was also made public, clearly describing the strategy to bypass FinCEN tools and Western blockchain analyses.
Half measures or strategic restraint?
According to the report, in April 2026 came to the surface that Iranian entities charged ship operators fees in cryptocurrencies for uninterrupted passage through the Strait of Hormuz. Cryptocurrency has reportedly become one of the main payment options for these transactions.
This seems to have been the practice quite successfulsuggesting that digital assets will continue to be used for similar purposes.
Against this background, adding Nobitex to the SDN List by analogy with Garantex may seem a logical step, even though such flows do not usually go through retail platforms. However, this did not happen.
US Treasury Department previously sanctioned Cryptocurrency exchanges linked to Iran, but these platforms were registered in the UK. However, Nobitex is registered in Iran as a purely local company.
Most importantly, on the same day, Reuters published its OFAC investigation into Nobitex explained that Iranian digital asset exchanges are already considered blocked financial institutions, regardless of whether they are individually listed on the SDN.
However, for a platform physically located in Iran, this has little practical effect: its core business is centered around Iranian users and neutral foreign intermediaries.
The SDN list works differently. This triggers secondary sanctions against any non-US counterparties around the world, provides direct justification for massive asset freezes by stablecoin issuers, and forces currency exchanges and OTC desks to sever ties or risk being designated themselves.
Why an individual SDN entry may be unnecessary
The US Treasury did not explain why Nobitex was not individually listed on the SDN exchange. However, it is worth noting that the department has never added platforms registered in Iran to this list – but there are several of them.
OFAC’s strategy towards the local cryptocurrency market in Iran is based on targeted measures. There are three main approaches:
- Sanctions against specific addresses.
- Replacement house designation – recent example involving the addition of exchanges ostensibly to handle state oil revenues.
- Designation of natural persons and OTC brokers.
As for Nobitex itself, any explanations can only be speculative. The first has already been outlined: OFAC is pursuing a different strategy against local Iranian platforms, and Nobitex simply fits within that logic, not outside of it.
The U.S. Treasury may also deem such measures unnecessary. As previously noted, U.S. persons are no longer permitted to transact on Iranian exchanges; from the point of view of formal access, individual entry does little to address existing restrictions.
There is also the “human shield” hypothesis. In an interview with Reuters, Nick Shrewd, director of intelligence at Crystal Intelligence, excellent that there is a high concentration of activity of ordinary Iranians on the platform. He suggested that separating the regime from the citizens who operate the stock market is almost impossible because their assets are commingled.
In this context Garantex case looks like the opposite scenario: the platform acted as a B2B node for gray capital. This made it possible to physically take over its servers without causing any social harm to retail users.
There is no direct public confirmation that this is OFAC’s stopping logic.
Finally, the attack on Nobitex may be perceived as less effective without a simultaneous move against external exits. The value of sanctions is not created at the “entry point”, but where the funds leave the country: on exchanges, stablecoin issuers, OTC brokers, banks and other intermediaries.
A double-edged sword
The Nobitex case is another reminder that the mass adoption the industry dreams of is a double-edged sword.
On the one hand, the stock market gives Iranians cut off from the world a measure of financial freedom: a way to protect their savings against rial inflation and maintain at least partial access to dollar liquidity. On the other hand, the state uses the same infrastructure for its own purposes, ranging from central bank currency interventions to transfers to regional proxies.
The bottom line is that this is no longer an isolated practice. Chain analysis places Iran, Russia and North Korea, noting that for all three countries, “what were once experimental and opportunistic tactics have matured into institutionalized strategies embedded in national economic and security policies.”
The Iranian model – a mass retail platform located in an inaccessible territory combined with foreign proxy structures – looks like a working template. Future sanctioned regimes will likely benefit from this experience.
This raises the opposite question – this time for the regulatory authorities themselves.
What is the acceptable cost of sanctions pressure when the regime’s funds and the savings of millions of ordinary users are physically combined on a single platform? Is it possible to freeze the assets of 11 million people to cut off the state’s financial channel – or is this exactly the line that the SDN mechanism in its current form does not cross?
OFAC has yet to provide a public response, and the Nobitex case has only intensified the debate.
