Syria Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Central Bank of Syria Circular No, Central Bank of Syria's, Main Central Bank, Anti-Money Laundering and Counter-Terrorism Financing Commission
Primary Legislation: The Caesar Syria Civilian Protection Act of 2019 was repealed on December 18, 20, No Syrian law, decree, circular, or regulation requiring a license or registrati
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: 2018 Decree: The CBS initially issued Circular No. 2/M.J.D. of 2018 (though exact English references and stable URLs are hard to find, this is widely reported) prohibiting dealing in cryptocurrencies.. Subsequent Reaffirmations: The ban has been reaffirmed multiple times, with the CBS warning citizens against dealing in virtual currencies due to their perceived risks to financial stability, lack of regulatory oversight, and potential for money laundering and terrorist financing. The Syrian authorities view cryptocurrencies as a threat to the national currency and economy.. No specific framework: Given the outright ban on cryptocurrency, there is no specific capital gains tax framework for virtual assets in Syria.. Illegal activity: Any profits made from crypto trading would arise from an illegal activity and would not be subject to a legal tax regime. Instead, individuals caught dealing in crypto could face criminal charges and confiscation of assets.. No specific framework: Similarly, there is no specific income tax regime for earnings derived from cryptocurrency activities (e.g., mining, staking, or income from crypto-related services).

Key Facts

aml Prohibition: The Central Bank of Syria (CBS) has repeatedly issued warnings and directives prohibiting the use and trading of cryptocurrencies. Criminalization: Law No. 36 of 2022 (issued in November 2022) explicitly criminalizes various activities related to cryptocurrencies, including their use as a payment method, trading, and promotion. Penalties are severe, including imprisonment and hefty fines. Legislative Decree No. 33 of 2005 on Anti-Money Laundering: This was the foundational AML law. Law No. 33 of 2014 amending Legislative Decree No. 33 of 2005: This significantly updated and strengthened the AML framework, particularly to address terrorism financing. It incorporated a risk-based approach and expanded the scope of reporting entities. Legislative Decree No. 27 of 2013 on Counter-Terrorism Financing: This decree specifically addresses the financing of terrorism, establishing measures and penalties. Identification and Verification: Obtaining and verifying the identity of customers (individuals and legal entities) using reliable, independent source documents, data, or information. This includes names, addresses, dates of birth, national ID numbers, etc., for individuals, and registration details, beneficial ownership, and control structure for legal entities. Beneficial Ownership Identification: Identifying and taking reasonable measures to verify the identity of the beneficial owner(s) of customers, including for legal persons and arrangements. Purpose and Nature of Business: Understanding the purpose and intended nature of the business relationship.
custody Explanation: Since cryptocurrencies are prohibited, there are no licensing frameworks for any entities (including financial institutions) to provide custodial services for digital assets. Engaging in such activities would likely be considered a violation of the existing ban. Explanation: With no legal framework for digital assets or custodial services, there are no rules mandating the segregation of client assets. Explanation: No insurance or bonding requirements exist for digital asset custodians, as the activity itself is not permitted. Explanation: There are no specific technical requirements or mandates for cold storage, hot storage, or any other security protocols related to digital asset custody, given the blanket prohibition. Explanation: The concept of a "qualified custodian" for digital assets does not exist within Syrian law, as the underlying assets are not recognized or permitted. Status: There is no publicly available information or indication of pending legislation in Syria specifically addressing the regulation or custody of digital assets. Given the current outright ban and the country's economic and political circumstances, the focus remains on enforcing the prohibition rather than developing regulatory frameworks for legal crypto activities. Central Bank of Syria (CBS) Circular/Decision (March 2021): In March 2021, the Central Bank of Syria issued a directive explicitly banning all dealings in cryptocurrencies, considering them "illegal." This decision was reportedly aimed at protecting citizens from risks associated with "speculation and fraud" and ensuring monetary stability, especially in the context of international sanctions and economic challenges. Official Reference (Difficult to obtain direct URL in English): Direct official links to Syrian Central Bank decrees in English are often not publicly available or easily accessible online. However, the ban was widely reported by reputable news agencies.
enforcement Regulator Name: Central Bank of Syria (CBS) Entity Targeted: All individuals and institutions within Syria engaging in or promoting cryptocurrency activities. This is a blanket prohibition rather than targeting a single entity. Violation Type: Engaging in, trading, promoting, or possessing virtual currencies, deemed illegal and subject to severe penalties under Syrian law. The CBS views these activities as speculative, highly risky, and a threat to the national currency and financial stability. Penalty Amount: No specific monetary penalty was announced for the policy itself. However, violations of this ban would likely incur severe penalties under existing Syrian laws related to financial crimes, illegal currency trading, or activities undermining the state's economic stability. These could include fines, asset forfeiture, and imprisonment, though specific case outcomes are not publicly disclosed. Date: The CBS issued definitive warnings and circulars reiterating the prohibition throughout late 2022 and early 2023. While specific circular numbers or exact dates are not always widely publicized internationally, news reports consistently cite this period for the renewed and forceful stance. Outcome: All cryptocurrency activities (trading, mining, possession, promotion) are officially illegal within Syria. This directive empowers authorities to crack down on anyone found dealing with digital assets. Reports from within Syria, though anecdotal and difficult to verify with official sources, suggest individuals have faced arrest and asset seizure for cryptocurrency-related activities following this ban. Al-Monitor: "Syria’s central bank bans cryptocurrency trading" (February 2, 2023) Reuters: "Syria's central bank bans cryptocurrency trading" (January 31, 2023) https://www.reuters.com/markets/currencies/syrias-central-bank-bans-cryptocurrency-trading-2023-01-31/ (Note: May require subscription to view full article on Reuters directly, but the headline and summary are widely reported.) The National News: "Syria central bank bans cryptocurrency trading" (February 1, 2023)
general None. Syria does not employ a "Howey Test equivalent" or any specific legal test to classify cryptocurrency tokens as securities. The regulatory stance is a blanket prohibition on all cryptocurrency-related activities. The legal basis for this prohibition stems from the Central Bank's mandate to protect the national currency (Syrian Pound), maintain financial stability, and combat illicit financial activities and capital flight, especially given the context of international sanctions. Not applicable. No specific cryptocurrency tokens are "considered securities" under a distinct regulatory framework. Instead, all forms of cryptocurrencies (Bitcoin, Ethereum, stablecoins, altcoins, NFTs with financial characteristics, etc.) are generally treated as prohibited or illegal financial instruments. The focus is on the activity of dealing with them (buying, selling, mining, holding, transferring) rather than their specific classification as a type of security. None. Since all cryptocurrency activities are prohibited, there are no legal registration or exemption requirements for token issuers. Issuing new tokens in or from Syria would be an illegal activity. None. There are no specific rules for secondary trading of tokens because all trading (primary or secondary) is prohibited. Any platform or individual facilitating such trading would be operating illegally. Arrests and Prosecution: Individuals involved in trading, mining, or facilitating cryptocurrency transactions have been arrested and prosecuted. Penalties can include fines and imprisonment. Blocking Access: Authorities may attempt to block access to cryptocurrency exchanges and related websites from within Syria.
licensing None are available or required. Engaging in these activities with cryptocurrencies is generally prohibited under current Syrian financial regulations. Any entity attempting to operate such services would be doing so outside the legal framework and would face severe legal repercussions. Neither a registration nor a licensing regime exists for virtual assets. The regime is one of prohibition. Irrelevant. Since the activities are prohibited, there are no prescribed requirements for capital, AML/KYC policies (specific to crypto, general financial AML/KYC still applies to traditional finance), or local presence for crypto businesses. There is no application process for cryptocurrency licenses or registrations, as these are not issued. Central Bank of Syria Circular No. 6/M.A. (2021): Content: This circular, issued by the CBS, explicitly warns against dealing in cryptocurrencies, stating that they are illegal and involve high risks for users. It clarifies that cryptocurrencies are not recognized as legal tender in Syria and that dealing in them violates Syrian financial laws. Specific Prohibition: It prohibits individuals and entities from creating, promoting, trading, or using any form of virtual currencies within Syria.
sanctions Syrian Sanctions Regulations (SSR): Prohibitions: Broadly prohibits U.S. persons from engaging in most financial transactions, trade, and investment with Syria, its government, and certain designated entities or individuals. This includes providing any services (financial or otherwise) that would benefit the Syrian government or its affiliates. Application to Crypto: U.S. persons (including U.S.-based VASPs, or non-U.S. VASPs using U.S. correspondent banking relationships or U.S.-based cloud infrastructure) are prohibited from facilitating, processing, or otherwise engaging in virtual currency transactions that involve, directly or indirectly, Syria, the Syrian government, or any Specially Designated Nationals (SDNs) linked to Syria. Syrian Sanctions Regulations (31 CFR Part 542): https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-542 Purpose: Imposes additional sanctions targeting foreign persons who provide significant financial, material, or technological support to the Syrian government or its officials, or who engage in specific economic activities (e.g., related to petroleum, military support, reconstruction, or aircraft maintenance). Application to Crypto: This act expands the scope of potential secondary sanctions, meaning non-U.S. VASPs could face U.S. sanctions if they knowingly facilitate significant virtual currency transactions for persons or entities involved in activities sanctioned by the Caesar Act, even if those persons are not explicitly on the SDN list. Caesar Syria Civilian Protection Act of 2019 (Public Law 116-92, Subtitle C, Section 7401-7431): Available via U.S. Congress website, e.g., https://www.congress.gov/bill/116th-congress/house-bill/2043 (See the enrolled bill text linked from this page) OFAC Guidance on Virtual Currency:
stablecoin Stablecoins are not officially classified under any of these categories within a regulatory framework, as they are not recognized or permitted to operate. They are treated as unauthorized digital currencies or virtual assets, subject to a general prohibition. Presidential Decree No. 4 of 2021 (amending Law No. 34 of 2005 - Anti-Money Laundering and Counter-Terrorist Financing Law): This is the cornerstone of the prohibition. Content: This decree criminalized dealing in, promoting, or trading unauthorized digital currencies within Syria. It introduced severe penalties, including imprisonment and hefty fines, for individuals and entities involved in such activities. The primary aim is to prevent money laundering, terrorist financing, and capital flight, as well as to protect the national currency (Syrian Pound) from further instability. Reference: While a direct official English translation of the decree with a public URL is often difficult to find from Syrian government sources, its existence and content have been widely reported by state media and regional news outlets. General reference: The decree amends Law No. 34 of 2005 on Combating Money Laundering and Terrorist Financing. News reports confirming the decree: You can find mentions in reports from outlets like SANA (Syrian Arab News Agency) or various Middle Eastern financial news portals from early 2021. For example, a search for "Syrian Presidential Decree 4 2021 cryptocurrency" will yield relevant news. Content: The CBS has repeatedly issued warnings and circulars to the public and financial institutions, reiterating the illegality of dealing in cryptocurrencies and advising against their use due to high risks, lack of regulatory oversight, and potential for fraud and financial crimes. These warnings reinforce the penalties stipulated in Decree No. 4 of 2021.
status There is no specific legal framework for cryptocurrency or digital assets in Syria; the provided sources contain zero references to cryptocurrency, digital assets, virtual currency, blockchain, or related terms. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status No Syrian regulatory authority is identified in these sources as having jurisdiction over digital assets, and no licensing or registration regime for crypto businesses exists under the materials reviewed. Temporary Protected Status Designated Country: Syria | USCIS The only authorities mentioned are U.S. agencies (OFAC, USCIS, DHS) addressing sanctions and immigration status, which do not constitute a domestic Syrian crypto regulatory framework. Syria Sanctions - Inactive and Archived | Office of Foreign Assets Control Businesses considering crypto operations in Syria face an absence of domestic law, meaning any activity would be governed by general financial and commercial statutes not addressed in these sources. Federal Register :: Amendment to the Syria-Related Sanctions Regulations The sources provided relate exclusively to U.S. legal actions concerning Syria—specifically the termination of Temporary Protected Status (TPS) and the revocation of comprehensive sanctions—not to any Syrian domestic regulatory framework for financial services or digital assets. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status The U.S. Department of Homeland Security (DHS) and U.S. Citizenship and Immigration Services (USCIS) terminated Syria's TPS designation effective November 21, 2025, pursuant to INA section 244(b)(3)(B), 8 U.S.C. 1254a(b)(3)(B), after determining Syria no longer met the conditions for designation. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status The U.S. Supreme Court in Mullin v. Doe, 609 U.S. ____ (2026), issued a favorable decision concerning TPS terminations, and the Syria TPS designation was terminated effective July 27, 2026. Temporary Protected Status Designated Country: Syria | USCIS The Secretary of Homeland Security determined that Syria no longer continues to meet the conditions for TPS designation after reviewing country conditions and consulting with appropriate U.S. Government agencies, with the designation set to expire September 30, 2025. Federal Register :: Termination of the Designation of Syria for Temporary Protected Status
tax 2018 Decree: The CBS initially issued Circular No. 2/M.J.D. of 2018 (though exact English references and stable URLs are hard to find, this is widely reported) prohibiting dealing in cryptocurrencies. Subsequent Reaffirmations: The ban has been reaffirmed multiple times, with the CBS warning citizens against dealing in virtual currencies due to their perceived risks to financial stability, lack of regulatory oversight, and potential for money laundering and terrorist financing. The Syrian authorities view cryptocurrencies as a threat to the national currency and economy. No specific framework: Given the outright ban on cryptocurrency, there is no specific capital gains tax framework for virtual assets in Syria. Illegal activity: Any profits made from crypto trading would arise from an illegal activity and would not be subject to a legal tax regime. Instead, individuals caught dealing in crypto could face criminal charges and confiscation of assets. No specific framework: Similarly, there is no specific income tax regime for earnings derived from cryptocurrency activities (e.g., mining, staking, or income from crypto-related services). Illegal activity: Any income generated from such activities would stem from an illegal source and would not be legally taxable. No applicable treatment: As cryptocurrency transactions are prohibited in Syria, there is no applicable VAT (Value Added Tax) or GST (Goods and Services Tax) treatment for virtual assets or related services. The Syrian tax system does have a Sales Tax (similar to VAT) on goods and services, but it would not apply to illegal crypto activities. None for crypto specifically: Since cryptocurrency activities are illegal, there are no official reporting requirements for individuals or businesses related to crypto holdings, transactions, or profits. Instead, authorities would be focused on detecting and prosecuting illegal crypto usage.
travel rule No specific cryptocurrency or digital asset legislation exists in Syria, and no travel-rule framework has been implemented as of 2025–2026. Syria Travel Advisory | Travel.State.gov Syria has no designated financial regulator overseeing virtual assets, and no licensing or registration regime for crypto businesses has been established. Syria – Level 4: Do Not Travel - U.S. Embassy in Syria No entities have been licensed to operate cryptocurrency exchanges or VASP activities in Syria. The Travel Advisory for Syria has been Level 4 (“Do Not Travel”) - U.S. Embassy in Syria The country is in an active armed conflict since 2011, with no functioning central regulatory apparatus for financial innovation. Travel Advisory: Syria - Level 4 (Do Not Travel) Practical reality: any crypto business operates entirely outside legal certainty, with no travel-rule compliance obligations, no supervisory authority, and no enforcement framework. Syria Travel Advisory | Travel.State.gov No regulatory body in Syria has been designated to oversee cryptocurrency, digital assets, or virtual asset service providers. Syria – Level 4: Do Not Travel - U.S. Embassy in Syria No primary law, decree, or official gazette publication establishing a legal framework for digital assets has been identified. The Travel Advisory for Syria has been Level 4 (“Do Not Travel”) - U.S. Embassy in Syria There is no named authority responsible for virtual asset regulation, licensing, or supervision in Syria. Travel Advisory: Syria - Level 4 (Do Not Travel)

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile