Syria

Okay, here is the comprehensive report on the current status of retail cryptocurrency trading in Syria, prepared with the perspective of a specialized financial regulatory analyst.

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**Report: Retail Cryptocurrency Trading Status in Syria**

**Date:** April 12, 2025

**Topic: Retail_Trading_Status**

**Description:** This section assesses the legal permissibility for individual citizens and residents in Syria to buy, sell, and hold cryptocurrencies. It details the regulatory environment, including any specific requirements or official warnings related to this activity.

**1. Current Status:** **Unclear**

**2. Detailed Narrative Explanation:**

The status of retail cryptocurrency trading in Syria is currently assessed as **Unclear**. This determination stems from a conflict between existing restrictive laws enacted under the previous government and recent, significant developments following the change in regime in late 2024, including a high-profile proposal for legalization that has yet to be formally adopted.

**Historical Context and Existing Restrictions:**

*   Under the previous government, Syrian law did not explicitly mention cryptocurrencies but contained provisions that effectively restricted or banned their use. Presidential Decree No. 54 of 2013, amended by Law No. 3 of 2020, explicitly prohibited the use of any currency other than the Syrian Pound (SYP) for payments, commercial transactions, or debt settlements within Syria. This decree applied broadly to individuals and entities providing goods or services.
*   Cryptocurrencies were not legally recognized under key Syrian legislation. They did not meet the definition of legal tender (Syrian Currency Act of 2002), foreign currency (Act No. 6 of 2000), securities (Securities Act of 2005), or commodities (Domestic Trade and Consumer Protection Act of 2015). Consequently, there was no legal basis for their formal use or trading within the regulated financial system.
*   No licenses were available for cryptocurrency-related activities, and financial institutions were implicitly, if not explicitly, barred from facilitating such transactions due to the aforementioned currency laws and the lack of regulatory framework.
*   Adding to the restrictive environment, the Syrian Islamic Council issued a fatwā (religious ruling) in November 2019 declaring cryptocurrencies like Bitcoin *ḥarām* (forbidden) based on factors including their digital-only existence, lack of backing by physical assets or state authority, absence of regulation, and inherent high risks.

**Recent Developments and Basis for Uncertainty (Post-December 2024):**

*   Following the collapse of the Assad regime in December 2024, a transitional government was formed. This political shift has opened the door to potential policy changes across various sectors, including finance.
*   In late December 2024 / early January 2025, the Syrian Center for Economic Research (SCER), described as a non-governmental think tank, put forward a significant proposal to the transitional government. This proposal advocates for the legalization of Bitcoin and potentially other cryptocurrencies for trading, mining, and financial transactions.
*   The SCER proposal is part of a broader strategy aimed at stabilizing Syria's war-torn economy, combating hyperinflation, attracting foreign investment, facilitating remittances (a crucial income source for many Syrians), and potentially digitizing the Syrian Pound using blockchain technology, possibly backed by assets including gold, USD, and Bitcoin.
*   The proposal explicitly mentions the need for strict oversight by the Central Bank of Syria to ensure transparency, security, and accountability if legalization proceeds. It also acknowledges the potential for cryptocurrencies to help bypass international sanctions, a tactic observed in other sanctioned nations like Iran and Russia, but also notes the associated geopolitical risks.
*   Crucially, this initiative is currently **only a proposal** from a research body and has **not** been formally adopted or enacted into law by the Syrian transitional government as of early 2025. The government's official position on cryptocurrency remains undeclared.

**Practical Realities and Regulatory Gaps:**

*   Despite the previous restrictive legal environment, some level of cryptocurrency activity has occurred. Chainalysis noted that while broad adoption was not observed, some Syrians have accessed foreign cryptocurrency platforms. There have also been reports of illicit use, such as fundraising by groups like Hay'at Tahrir al-Sham (HTS).
*   Major international cryptocurrency exchanges, like Binance, do not officially operate in Syria, citing regulatory restrictions and classifying the legal status as unclear.
*   Given the lack of formal recognition or regulation, there are no specific KYC (Know Your Customer) or AML (Anti-Money Laundering) requirements imposed on cryptocurrency platforms operating within Syria, as such operations are not legally sanctioned.

**Conclusion:**

The confluence of old restrictive laws (specifically Decree 54/2013 mandating the use of SYP) and the lack of any legal framework permitting cryptocurrencies points towards a historically `Banned` or `Restricted` environment. However, the recent dramatic political changes and the active, widely reported proposal by the SCER to legalize Bitcoin introduce significant uncertainty. It is unclear whether the old laws are being strictly enforced by the new administration or if a policy shift is imminent. Until the transitional government makes an official pronouncement or enacts new legislation, the legal status for retail cryptocurrency trading remains ambiguous, hence **Unclear**.

**3. Relevant Text Excerpts:**

*   **On the Ban of Non-SYP Transactions (Pre-existing Law):**
    *   "Under section 1(I), Presidential Decree No. 54 of 2013 and its amendment No. 3 of 2020 has banned the use of any currency or precious metals as means of payment, commercial transaction or even repayment of debt other than the Syrian pound. This decree includes persons delivering products or services."
        *   *Source:* ResearchGate (Summarizing Syrian Law) / The Currency Analytics
*   **On Lack of Legal Recognition (Pre-existing Law):**
    *   "Cryptocurrency is not yet recognized, allowed, or licensed under any Syrian law. Hence, cryptocurrency is not legally considered a commodity by the Domestic trade and consumer protection Act of 2015." ... "Cryptocurrency cannot be classified as a security because it did not fall under the definition of securities per the Securities Act of 2005 in Syria." ... "Thus, cryptocurrency is not classified or recognized as a currency [under the Syrian Currency Act of 2002]."
        *   *Source:* ResearchGate (Summarizing Syrian Law) / The Currency Analytics
*   **On the Recent Legalization Proposal (Jan 2025):**
    *   "Syria is considering legalizing Bitcoin and digitizing the Syrian pound as part of an ambitious plan to stabilize its war-torn economy and attract global investments. Proposed by the Syrian Center for Economic Research (SCER), the initiative aims to address economic instability, inflation, and financial exclusion through blockchain technology and cryptocurrency adoption."
        *   *Source:* FXStreet / Binance News / Multiple sources reporting on SCER proposal.
    *   "The SCER addresses this by outlining a comprehensive plan that incorporates digitalization of the Syrian pound using blockchain technology and the legalization of Bitcoin for financial transactions, trading, and mining. By using assets such as gold, US dollars, and Bitcoin as backing, this strategy hopes to stabilize the currency."
        *   *Source:* Binance News / FXStreet
    *   "The proposal emphasizes strict oversight by the central bank to ensure transparency, security, and accountability in cryptocurrency operations."
        *   *Source:* FXStreet / CryptoRank / CoinMarketCap
*   **On Current Access and Platform Availability:**
    *   "Binance does not currently operate in Syria. The platform's services are not available to users in the region... This unavailability is likely due to regulatory and legal restrictions..." It also notes: "Regulatory Uncertainty: The legal status of cryptocurrency in Syria is unclear, posing potential risks."
        *   *Source:* OneSafe Blog
    *   "We have not observed broad crypto adoption in Syria. Nonetheless, Syrians have found ways to open accounts on foreign platforms..."
        *   *Source:* Chainalysis
*   **On Religious Stance:**
    *   "In November 2019, the Syrian Islamic Council (SIC) issued a fatwā declaring that cryptocurrencies “like bitcoin” were ḥarām, or forbidden... the Council based its ruling on several considerations: that cryptocurrencies exist only digitally, are not backed by gold or fiat currencies, and operate outside a state or other centralized legal apparatus and therefore cannot be regulated."
        *   *Source:* Harvard Law School Islamic Finance Project (SHARIAsource)

**4. Source URLs:**

*   **ResearchGate (Analysis of Syrian Legislation pre-2021):**
    *   `https://www.researchgate.net/publication/342160978_AN_INVESTIGATION_FOR_A_LEGAL_FRAMEWORK_GOVERNING_CRYPTOCURRENCIES_UNDER_THE_SYRIAN_LEGISLATION_AN_ANALYTICAL_STUDY` (Provides analysis leading to excerpts on Decree 54 and lack of legal recognition)
*   **The Currency Analytics (Similar Analysis pre-2022):**
    *   `https://thecurrencyanalytics.com/altcoins/bitcoin-and-cryptocurrency-are-not-illegal-or-legal-per-syrian-laws-39744.php` (Corroborates analysis of Decree 54 and lack of legal status)
*   **FXStreet (SCER Proposal Report):**
    *   `https://www.fxstreet.com/cryptocurrencies/news/syria-eyes-bitcoin-legalization-to-revive-war-torn-economy-202501020800`
*   **Binance News (SCER Proposal Report):**
    *   `https://www.binance.com/en/square/post/20250102-to-help-rebuild-its-war-torn-economy-syria-is-considering-legalizing-bitcoin-5130000313117`
*   **CryptoRank (SCER Proposal Report):**
    *   `https://cryptorank.io/news/feed/531a3-syria-proposes-to-legalize-bitcoin-for-economic-recovery`
*   **CoinMarketCap (SCER Proposal Report):**
    *   `https://coinmarketcap.com/community/articles/6592b03e7714036334708f79/`
*   **OneSafe Blog (Binance Availability & Status):**
    *   `https://onesafe.ai/blogs/does-binance-work-in-syria`
*   **Chainalysis (Usage Context & Sanctions):**
    *   `https://www.chainalysis.com/blog/cryptocurrency-syria-war-zone-update/`
*   **Harvard Law School - SHARIAsource (Syrian Islamic Council Fatwa):**
    *   `https://islamicfinancenews.com/daily-cover-story/fatwas-on-cryptocurrency-the-syrian-islamic-council-and-the-international-union-of-muslim-scholars-al-qaradaghi/` (Original SHARIAsource link might be behind paywall/login, this article discusses it) or potentially `https://beta.shariasource.com/documents/4451` (Cited in the article, may require login).

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**Disclaimer:** This report reflects the understanding of the regulatory landscape based on available public sources as of the date indicated. The situation in Syria is fluid, particularly given the recent political transition. Official clarification from the Syrian transitional government or the Central Bank of Syria would be required for a definitive status determination.