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Remote VASP serving residents in Syria

Foreign-incorporated entity that offers exchange, custody, or transfer services to residents of a jurisdiction without establishing a local entity or office.

Not permitted AI-Generated · Unreviewed

Remote VASP 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 obligations exist for crypto services because the activity itself is prohibited — Law No. 36 of 2022 criminalizes trading, use, and promotion of cryptocurrencies.
  • However, general Syrian AML law (Law No. 33 of 2005 as amended by Law No. 33 of 2014) imposes CDD, EDD, STR, and recordkeeping obligations on financial institutions — but these do not apply to prohibited crypto activities.
  • Engaging in crypto services carries criminal penalties under Law No. 36 of 2022, including imprisonment and fines.
  • Syria is subject to international sanctions, making any financial activity involving crypto extremely high-risk from an international compliance perspective.

Key Restrictions

  • Crypto activities are outright prohibited — Central Bank of Syria Circular No. 6/M.A. (2021) and Circular No. 1040/M.S. (March 2021) ban dealing in virtual currencies.
  • Law No. 36 of 2022 criminalizes use of crypto as payment, trading, and promotion, with severe penalties including imprisonment and fines.
  • No licensing or registration regime exists — the regime is one of prohibition, not permission.
  • A foreign-incorporated entity serving Syrian residents from abroad is still engaging in prohibited activities and subject to legal prosecution if enforcement reach extends.

Key Risks

  • Legal prosecution risk: imprisonment and fines under Law No. 36 of 2022 for engaging in crypto activities.
  • Blocking of funds and accounts by Syrian authorities.
  • International sanctions exposure: Syria is under international sanctions, and unlicensed crypto services involving Syrian residents raise sanctions compliance risks.
  • Reputational and legal risk from operating in a jurisdiction where the activity is criminally prohibited.
  • Enforcement actions by the Central Bank of Syria (CBS) and AMLCFTC are possible, with reported crackdowns on crypto dealing.

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

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.

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.

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.

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.

No — remote VASPs cannot serve Syrian residents because all cryptocurrency activities are prohibited under Central Bank of Syria directives and Law No. 36 of 2022, with no licensing or registration regime available, and violators face criminal prosecution, imprisonment, and fines.

Questions this verdict aims to answer

  • May a non-resident provider serve residents from abroad?
  • Does cross-border service trigger licensing, registration, or AML obligations?
  • What enforcement risk exists for unlicensed remote operators?