Although Iran’s internet officially remained part of global routing, user activity decreased to almost zero. This represents a controlled restriction on public access to external networks. sauce: IOD.
But even in that digital darkness, one essential financial service continued to operate uninterrupted. That is Nobitex, a cryptocurrency exchange. linked to Iran’s ruling elite.
We compiled available information about this platform and sought to understand how Iranian authorities are using it, what an investigation by an analytical firm revealed, and why, despite all these findings, this exchange is still not on OFAC’s SDN list.
The size and scope of Iranian crypto giants
Nobitex is far from a niche platform. Although estimates vary, analysts agree that the flow of assets through exchanges is in the billions of dollars. For example, TRM Institute recorded The observed transaction value from 2025 to March 2026 is approximately $5 billion.
Previously, Chainalysis noted that asset inflows to Nobitex addresses exceeded the combined value of Iran’s other 10 largest exchanges. sauce: chain analysis.
Nobitex has an extensive retail user base. According to the platform: my numbersserves approximately 11 million Iranians, representing almost 12% of the country’s population.
The exchange offers a suite of industry-typical services, including spot and margin trading, high-yield products, liquidity pools, digital gift cards, and even cryptocurrency-backed lending.
Nobitex also caters to professional market participants and institutional investors. These entities are provided Contains technical terms such as increased limits and fast API.
But it’s not the retail business that has brought attention to the platform. The information suggested that Novitex was functioning as a currency gateway for countries that were separated from SWIFT.
shadow banking network
A series of studies available online focus on how Novitex is helping Iranian leaders evade economic sanctions.
January 2026, Ellipse A report has been published It details the systematic purchase of the USDT stablecoin by the Central Bank of Iran. The company said transactions totaling at least $507 million were conducted through brokers in the UAE, with the assets going “primarily” to Nobitex.
Because stablecoins can be sold for real, regulators were effectively intervening in foreign exchange outside the international banking system.
This is not the only use of state exchange. recent Reuters survey It links the platform’s founders, brothers Ali and Mohammad Karaji, with one of the country’s most influential political and clerical families.
The agency also certified that one of the largest early investors in the exchange was Mohammad Baqer Nahavi, vice president of Safiran Airport Services. placed Will be placed on OFAC SDN list in September 2022 for organizing flights to supply Iranian drones to Russia.
Separately, oval and chain analysis It documents Nobitex’s ties to wallets associated with Hamas, the Houthi Ansar Allah movement, the propaganda agency Gaza Now, and the licensed Russian exchange Galantex.
The exchange itself appears to have been building infrastructure to operate under sanctions from the beginning.
In June 2025, the platform’s source code and some internal documentation were made public. leaked online. According to this data, the code included modules for stealth address generation, transaction batching and splitting, endpoint switching, and specific logic designed to bypass compliance checks. A document titled “Nobitex Privacy” was also published, explicitly explaining strategies to circumvent FinCEN tools and Western blockchain analysis.
Half-hearted measures or strategic restraint?
April 2026 Report surfaced An Iranian group was allegedly charging ship operators in cryptocurrencies for unobstructed passage through the Strait of Hormuz. Cryptocurrency has reportedly become one of the main payment options for these transactions.
The custom seems to have been as follows quite successfulsuggesting that digital assets will continue to be used for similar purposes.
Against this background, it may seem like a logical step to add Nobitex to the SDN list, similar to Garantex, even though such flows would not normally pass through a retail platform. But that hasn’t happened yet.
US Treasury previously approved Although the cryptocurrency exchanges are linked to Iran, these platforms were registered in the UK. On the other hand, Novitex incorporated We operate in Iran as a purely local company.
Importantly, on the same day, Reuters announced the results of its investigation into Nobitex and OFAC. clarified Iranian digital asset exchanges are already considered blocked financial institutions, whether or not they are individually named on the SDN list.
However, for platforms physically based in Iran, this has little practical impact. Its core operations revolve around Iranian users and neutral foreign intermediaries.
The SDN list functions differently. This would trigger secondary sanctions against non-US counterparties around the world, provide direct justification for bulk asset freezes by stablecoin issuers, and force foreign exchanges and OTC desks to disengage or risk designation.
Why are individual SDN lists redundant?
The US Treasury has not explained why Nobitex’s separate SDN listing did not follow. However, it is worth noting that the ministry has never added Iranian-embedded platforms to the list. some of them.
OFAC’s strategy for Iran’s domestic cryptocurrency market is built around targeted measures. Three main approaches stand out.
- Sanctions against specific addresses.
- Exchange designation – recent example This is in addition to an exchange purportedly servicing the country’s shadow oil revenues.
- Individual and OTC Broker Designations.
As for Novitex itself, any explanation is speculative. The first one has already been outlined. OFAC has adopted a different strategy toward Iran’s local platforms, and Nobitex simply fits within that logic rather than outside of it.
The US Treasury may also consider such measures unnecessary. As mentioned above, Americans are already prohibited from doing business with Iranian exchanges. From a formal access point of view, a separate list adds little to the existing restrictions.
There is also the “human shield” hypothesis. Nick Smart, chief information officer at Crystal Intelligence, told Reuters: noticed The platform reportedly hosts intensive activity by ordinary Iranians. He suggested that it would be nearly impossible to use exchanges to separate the regime and the people because their assets are intermingled.
In this context, Galantex incident Looks like the opposite scenario. The platform operates as a B2B hub for shadow capital. This made it possible to physically seize servers without causing social harm to retail users.
There is no direct public confirmation that this is the logic that precludes OFAC.
Finally, a strike against Nobitex could be seen as less effective without concurrent action on an external “exit.” The value of sanctions occurs not at the “gateway” but where funds exit the country: foreign exchanges, stablecoin issuers, OTC brokers, banks, and other intermediaries.
double edged sword
The Nobitex incident is yet another reminder that the industry’s dream of mass adoption is a double-edged sword.
On the one hand, the exchange is a way to give Iranians cut off from the rest of the world some economic freedom, protect their savings from real inflation, and maintain at least some access to dollar liquidity. States, on the other hand, use the same infrastructure for their own purposes, ranging from central bank monetary interventions to remittances to regional agents.
The important point is that this is no longer an isolated practice. chain analysis place Iran, along with Russia and North Korea, noted that all three countries have “matured what were once experimental and opportunistic tactics into institutionalized strategies embedded in national economic and security policies.”
The Iranian model – a mass-market platform based in an unreachable region combined with an offshore proxy structure – looks like a working template. Future sanctions regimes will likely draw on this experience.
This raises the opposite 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 intermixed on a single platform? Can the assets of 11 million people be frozen and the country’s financial channels cut off, or is that the line that the SDN mechanism in its current form will not cross?
OFAC has yet to issue a public response, and the Novitex scandal will only further sharpen the debate.
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