← Regulations / Syria / Operating Models / CEX

Centralized exchange in Syria

Order-book exchange that takes custody of user assets and matches trades between users.

Not permitted AI-Generated · Unreviewed

CEX is not permitted in Syria.

Verdict Details

Permitted
no
Local entity required
No
Licensing burden
None
Last updated
2026-07-13

AML Obligations

  • No AML/KYC requirements exist for this operating model because the activity itself is prohibited under Law No. 36 of 2022.
  • Engaging in cryptocurrency activities carries severe criminal penalties, including imprisonment and fines, under Law No. 36 of 2022.
  • Syria's general AML framework (Legislative Decree No. 33 of 2005, as amended by Law No. 33 of 2014) and CTF regime (Legislative Decree No. 27 of 2013) apply to traditional financial institutions but do not create a pathway for crypto exchanges.
  • Any attempted operation would run contrary to the CBS's prohibition and expose the operator to sanctions, fund freezes, and criminal prosecution.

Key Restrictions

  • All cryptocurrency dealing, trading, promoting, creating, and using is illegal in Syria per Central Bank of Syria directives and Law No. 36 of 2022.
  • No licensing or registration regime exists for virtual assets — the regime is one of outright prohibition.
  • International sanctions on Syria make any financial activity with Syrian nexus extremely high-risk from a compliance perspective.
  • Individuals and entities are prohibited from creating, promoting, trading, or using any form of virtual currencies within Syria.

Key Risks

  • Criminal prosecution (imprisonment and fines) under Law No. 36 of 2022 and CBS Circular No. 6/M.A. (2021).
  • Blocking of funds and accounts by authorities.
  • Designation as involvement in illegal financial activities, with potential implications under international sanctions regimes.
  • No legal framework exists — any exchange operating would be entirely outside the law with no recourse or legal protection.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 40% confidence

None are available or required. Engaging in these activities with cryptocurrencies is generally prohibited under current Syrian financial regulations.

licensing 40% confidence

Any entity attempting to operate such services would be doing so outside the legal framework and would face severe legal repercussions.

licensing 40% confidence

Neither a registration nor a licensing regime exists for virtual assets. The regime is one of prohibition.

licensing 40% confidence

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.

licensing 40% confidence

There is no application process for cryptocurrency licenses or registrations, as these are not issued.

licensing 40% confidence

Central Bank of Syria Circular No. 6/M.A. (2021):

licensing 40% confidence

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.

licensing 40% confidence

Specific Prohibition: It prohibits individuals and entities from creating, promoting, trading, or using any form of virtual currencies within Syria.

licensing 40% confidence

Consequences: The circular warns of legal prosecution for those found violating these directives.

licensing 40% confidence

Legal prosecution: Imprisonment and fines.

licensing 40% confidence

Blocking of funds and accounts.

licensing 40% confidence

Involvement in illegal financial activities, which could also have implications under international sanctions regimes due to Syria's status.

custody 20% confidence

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.

custody 20% confidence

Explanation: With no legal framework for digital assets or custodial services, there are no rules mandating the segregation of client assets.

custody 20% confidence

Explanation: No insurance or bonding requirements exist for digital asset custodians, as the activity itself is not permitted.

custody 20% confidence

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.

custody 20% confidence

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.

aml 40% confidence

Prohibition: The Central Bank of Syria (CBS) has repeatedly issued warnings and directives prohibiting the use and trading of cryptocurrencies.

aml 40% confidence

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.

aml 40% confidence

There are no legal AML/KYC requirements because the service itself is prohibited.

aml 40% confidence

Engaging in such activities carries significant criminal penalties under Law No. 36 of 2022.

aml 40% confidence

Furthermore, Syria is subject to international sanctions, making any financial activity, especially involving novel assets like crypto, extremely high-risk from an international compliance perspective.

enforcement 60% confidence

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.

enforcement 60% confidence

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.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
high

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Prohibited — operating a centralized cryptocurrency exchange in Syria is illegal under Central Bank of Syria Circular No. 6/M.A. (2021) and Law No. 36 of 2022, which criminalize all cryptocurrency dealing, trading, and promotion, with no licensing or registration path available.

Questions this verdict aims to answer

  • What exchange / VASP license applies?
  • What custody segregation rules apply to user assets?
  • What market-conduct and listing rules apply?
  • What travel-rule obligations apply on withdrawals?