Self-custodial wallet / non-custodial software in Syria
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet 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 attach — the activity (publishing software related to cryptocurrencies) itself is prohibited under Syrian law and thus cannot be lawfully carried out.
- Engaging in such activities carries significant criminal penalties under Law No. 36 of 2022 (imprisonment and fines).
- Syria's general AML framework (Law No. 33 of 2014, Legislative Decree No. 33 of 2005) applies to traditional finance, but is irrelevant here because the crypto activity is prohibited outright.
Key Restrictions
- Publishing software that enables cryptocurrency self-custody could be construed as 'promoting' or 'using' virtual currencies, which is prohibited under Central Bank of Syria Circular No. 6/M.A. (2021).
- Law No. 36 of 2022 criminalizes trading, use as payment, and promotion of cryptocurrencies — software distribution may fall under 'promotion'.
- No licensing or registration regime exists; there is no legal pathway to operate.
- Syria is subject to international sanctions, making any cross-border financial or software activity involving novel assets extremely high-risk.
Key Risks
- Legal prosecution under Law No. 36 of 2022, with penalties including imprisonment and fines.
- Seizure/blocking of funds and accounts by Syrian authorities.
- Classification of software publishing as 'promotion' of prohibited virtual currencies — enforcement precedent suggests blanket prohibition applies to all cryptocurrency-related activities.
- International sanctions exposure — any involvement with Syria carries secondary sanctions risk for foreign entities.
- Reputational risk from operating in a jurisdiction with an outright ban and opaque enforcement environment.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
Specific Prohibition: It prohibits individuals and entities from creating, promoting, trading, or using any form of virtual currencies within Syria.
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.
There are no legal AML/KYC requirements because the service itself is prohibited.
Engaging in such activities carries significant criminal penalties under Law No. 36 of 2022.
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.
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.
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.
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)
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.
Not permitted — Syria has an outright prohibition on cryptocurrency dealings under Central Bank of Syria Circular No. 6/M.A. (2021) and Law No. 36 of 2022, which criminalizes trading, use, and promotion of virtual currencies; self-custodial wallet software publishing is not exempt and carries risk of legal prosecution, with no licensing or registration pathway available.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?