Posted By Tristan Valehart On 14 Oct 2025 Comments (1)
Syria Sanctions Screening Tool
Check OFAC Sanctions List
This tool helps verify if entities or individuals are on the U.S. OFAC Specially Designated Nationals (SDN) List. This is critical for Syrian crypto compliance since 139 individuals and entities remain designated under Executive Order 13894.
Syria cryptocurrency regulatory environment is a patchwork of U.S. sanctions relief, lingering designations, and virtually no domestic crypto law. After the United States lifted most of its comprehensive sanctions on July 1, 2025, many assumed Syrian crypto users would be free to trade without hassle. In reality, businesses still face a maze of compliance steps, limited fiat on‑ramps, and a steep learning curve that can add weeks to any market‑entry plan.
Why the U.S. lifted sanctions and what changed
The shift began with Executive Order 14312, signed on June 30, 2025, which officially revoked the Syrian Sanctions Regulations (SySR) that had governed U.S. dealings since 2004. The Treasury’s Office of Foreign Assets Control (OFAC) removed SySR from the Code of Federal Regulations on August 26, 2025, and the Bureau of Industry and Security (BIS) issued a final rule on September 2, 2025 that opened the Export Administration Regulations (EAR) to most EAR‑99 items destined for Syria. The main effect? U.S. banks can now open correspondent accounts with Syrian banks, and crypto exchanges like Binance began accepting Syrian IP addresses.
What still blocks a smooth crypto experience
Even with the major sanctions removed, two major obstacles remain:
- Residual designations - 139 individuals and entities linked to the former Assad regime stay on the Specially Designated Nationals (SDN) List under Executive Order 13894. Any crypto transaction that touches these parties triggers a violation.
- Domestic legal vacuum - Syria has not passed any law that explicitly legalizes or bans crypto. The lack of clear AML/KYC rules means U.S. and international firms must rely on “enhanced due diligence” to prove they are not facilitating illicit activity.
The result is a compliance minefield. For example, Lightspark’s 2025 analysis estimates that 78% of cross‑border payments involving Syrian counterparties face additional verification, extending processing times by roughly 47hours compared with non‑sanctioned jurisdictions.
Step‑by‑step compliance checklist for crypto businesses
Below is a practical checklist that turns the abstract legalese into concrete actions. Follow it before you launch or expand services into Syria.
- Screen every counterparty against all 13 U.S. sanctions lists. Use a real‑time screening provider; manual lists become outdated within days.
- Verify that the transaction does not involve any of the 139OFAC‑designated individuals or entities. Flagged matches must be escalated to legal counsel.
- Obtain a written opinion confirming that the crypto activity does not fall under the Global Terrorism Sanctions Regulations or the Foreign Terrorist Organizations Sanctions Regulations, which are still enforced via General Licenses 24 and 25.
- Document the source of funds for every Syrian user. While Syrian law does not mandate this, U.S. regulators expect audit‑ready records for any transaction involving Syrian counterparties.
- Ensure your fiat on‑ramp partners (banks, payment processors) have corresponding accounts with the Central Bank of Syria (Central Bank of Syria) that are themselves cleared under the May2025 OFAC exceptive relief.
- Implement transaction monitoring thresholds aligned with the average $500 per‑transaction limit observed on Binance for Syrian users (Reddit, Sep2025). Anything above that should trigger a secondary review.
- Prepare to handle frequent account freezes. Maintain a rapid‑response team that can supply additional documentation within 24hours to prevent user churn.
Completing these steps typically takes 14‑16weeks, nearly double the timeline for other emerging markets where regulatory frameworks already exist.
Comparing the pre‑ and post‑sanctions crypto landscape
| Aspect | Before July2025 | After July2025 |
|---|---|---|
| U.S. legal basis for restrictions | Syrian Sanctions Regulations (SySR) under EO13338 | SySR removed; only residual EO13894 designations remain |
| Banking access for U.S. institutions | Prohibited correspondent accounts | Allowed with Central Bank of Syria under OFAC FAQ1221 |
| Crypto exchange access | Blocked by most platforms | Binance opened limited services; other exchanges cautious |
| Export controls on mining equipment | Full EAR licensing required | EAR99 items generally permitted; CCL items still need authorization |
| Typical transaction processing time | Several days to weeks due to sanctions checks | Average 47hours extra verification (Lightspark 2025) |
Market outlook and real‑world impact
Despite the regulatory fog, adoption is growing. Chainalysis estimates that about1.2million Syrians - roughly6% of the population - have interacted with crypto since July2025, mainly for remittances and cross‑border trade. The potential market size is significant: CoinDesk projects annual crypto transaction volume could reach$420million by 2027 if clear rules emerge.
However, user experience remains rough. Forum posts from r/CryptoSyria (Sep2025) describe mandatory identity verification, transaction caps of $500, and frequent account freezes. A Trustpilot snapshot of Binance reviews from Syrian IPs gave an average rating of 2.8/5, with 63% of negative feedback citing “excessive verification” and “sudden restrictions.”
Workarounds like peer‑to‑peer swaps or routing fiat through Lebanese and Jordanian banks are common, but they carry a 22% reported loss rate among users who tried such methods. Until Syria adopts a formal crypto framework, these stop‑gap solutions will dominate.
Practical advice for crypto firms eyeing Syria
If you’re considering entering the Syrian market, prioritize three pillars:
- Compliance infrastructure - Build or license a screening engine that updates all U.S. sanctions lists hourly and can flag the 139designated entities instantly.
- Local partnership strategy - Align with a Syrian bank that already has a U.S. correspondent account (e.g., Commercial Bank of Syria) to smooth fiat conversion.
- Risk‑adjusted product design - Offer low‑value, high‑frequency wallets that stay under the typical $500 cap, and keep transaction monitoring thresholds tight.
By treating the Syrian environment as a “transitional compliance zone,” you can reduce onboarding friction and avoid costly fines. Remember that the Caesar Act waiver is only 180days; a long‑term plan should anticipate future U.S. policy shifts.
Frequently Asked Questions
Can U.S. firms legally provide crypto services to Syrian residents?
Yes, but only after completing enhanced due diligence, ensuring no counterparties appear on the remaining OFAC SDN List, and operating under General Licenses24 and25. Direct facilitation of transactions involving the 139 designated individuals is prohibited.
What crypto exchanges currently accept Syrian users?
Binance opened limited services in July2025, but most other major exchanges (Coinbase, Kraken) still block Syrian IPs pending clearer regulations. Smaller regional platforms may allow access but often lack robust compliance tools.
How does the remaining OFAC designation affect crypto on‑ramps?
Any fiat on‑ramp that processes a payment to a designated entity triggers an OFAC violation. Firms must screen both the sender and receiver, and block or report any match immediately.
Is mining equipment subject to U.S. export controls?
Most ASICs and GPUs are classified as EAR99 and can be exported to Syria without a license, but any component on the Commerce Control List still requires a specific or general authorization under the new BIS rule.
What are the penalties for violating the residual sanctions?
Violations can result in civil penalties of up to $1million per violation, criminal fines, and loss of access to U.S. financial markets. The Treasury’s Office of Enforcement actively monitors crypto transactions for breaches.
Kim Evans
October 14, 2025 AT 09:00Thanks for pulling together this massive compliance checklist – it’s a solid starting point for anyone eyeing the Syrian market.
Remember to integrate a real‑time OFAC screening API; static lists become outdated in a matter of days.
Also, flagging the 139 designated entities early can save you weeks of back‑and‑forth with legal counsel.
Don’t forget to keep detailed source‑of‑funds records for each user; auditors love that stuff.
Good luck, and stay on top of those extra 47‑hour verification windows! 🙂