Syria

Retail_Trading_Status

Gray-Zone High Confidence

Analysis ID: #800
Version: Latest
Created: 2025-12-12 05:17
Run: 644ce117...
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Workflow Stage: Step 1

Executive Summary

As of December 2025, cryptocurrency in Syria occupies a legal gray area following the collapse of the Assad regime and the establishment of a transitional government. While the lifting of U.S. sanctions in May 2025 has allowed major international exchanges like Binance to service Syrian residents, no domestic regulatory framework has been enacted to legalize or supervise digital assets formally. Trading is tolerated and accessible, but cryptocurrency mining remains explicitly illegal due to severe energy shortages. The Syrian Center for Economic Research (SCER) has proposed legislation to formalize Bitcoin's status, but this has not yet been signed into law.

Key Pillars

Transitional Government of Syria (Current de facto authority)
Commission for Combating Money Laundering and Financing of Terrorism (CCMLFT) - Enforces AML/KYC
Central Bank of Syria (CBS) - Oversees monetary stability and foreign exchange
No dedicated Virtual Asset Service Provider (VASP) licensing regime exists yet

Landmark Laws

SCER Bitcoin Legalization Proposal (Draft Proposal)
- A comprehensive proposal by the Syrian Center for Economic Research to legalize Bitcoin for trading and payments and digitize the Syrian Pound to stabilize the economy.

Legislative Decree No. 5 of 2024 (Decree No. 5/2024) - Enacted: 2024-01-20
- Prohibits dealing in currencies other than the Syrian pound and imposes strict penalties. While primarily targeting foreign fiat, it creates a legal risk for crypto usage as a payment method until explicitly repealed or clarified.
- Source

Legislative Decree No. 33 (Decree No. 33)
- Governs AML/CFT compliance in Syria. Financial institutions and potential crypto service providers must adhere to KYC and suspicious transaction reporting under this framework.

Considerations

Cryptocurrency mining is explicitly banned due to critical energy infrastructure deficits.
U.S. sanctions were lifted in May 2025, removing the primary external barrier to crypto access.
The legal environment is transitional; legacy laws banning foreign currency usage (Decree No. 5) technically remain but enforcement against crypto trading appears suspended.
No consumer protection or deposit insurance exists for crypto assets.

Notes

The analysis reflects the specific simulated timeline where the Assad regime collapsed in late 2024 and US sanctions were lifted in May 2025. In this context, the 'Gray-Zone' status is driven by the gap between the practical openness of the market (Binance entry) and the lack of de jure legalization.

Remaining Uncertainties

Will the transitional government formally adopt the SCER proposal to legalize Bitcoin?
Does the legacy Decree No. 5 of 2024 apply to cryptocurrency transactions in court?
When will a formal licensing regime for VASPs be established?

Detailed Explanation

As of December 2025, cryptocurrency in Syria occupies a legal gray zone. This status is defined by a transitional environment where practical market access exists following the lifting of U.S. sanctions in May 2025, but no formal domestic legal framework has been enacted. Major international exchanges like Binance can now service Syrian residents, and trading is tolerated in practice. However, the absence of dedicated legislation means digital assets are not formally legalized or supervised, creating a gap between de facto activity and de jure recognition. The regulatory landscape is overseen by the Transitional Government of Syria, with the Central Bank of Syria (CBS) concerned with monetary stability and the Commission for Combating Money Laundering and Financing of Terrorism (CCMLFT) enforcing anti-money laundering rules. The key legislative backdrop includes Legislative Decree No. 33, which governs AML/CFT compliance and requires financial institutions and potential crypto service providers to adhere to KYC and suspicious transaction reporting. A significant legal risk stems from Legislative Decree No. 5 of 2024, enacted on 2024-01-20, which prohibits dealing in currencies other than the Syrian pound. While this decree primarily targets foreign fiat and enforcement against crypto appears suspended, it technically creates a legal risk for using cryptocurrency as a payment method until it is explicitly repealed or clarified. The most forward-looking development is the SCER Bitcoin Legalization Proposal, a comprehensive draft by the Syrian Center for Economic Research to legalize Bitcoin for trading and payments and digitize the Syrian Pound, but it has not yet been signed into law. A critical and explicit restriction is the ban on cryptocurrency mining due to severe energy shortages in the country. Furthermore, no consumer protection or deposit insurance exists for crypto assets, highlighting the nascent and uncertain nature of the current regulatory environment.

Summary Points

I. Regulatory Status
* Gray-Zone status as of December 2025.
* No formal domestic regulatory framework enacted; trading is tolerated but not formally legalized.
* U.S. sanctions were lifted in May 2025, enabling access to international exchanges.
* Legal environment is transitional following the collapse of the prior regime.

II. Key Regulatory Bodies
* Transitional Government of Syria: Current de facto authority.
* Central Bank of Syria (CBS): Oversees monetary stability and foreign exchange.
* Commission for Combating Money Laundering and Financing of Terrorism (CCMLFT): Enforces AML/KYC requirements.
* No dedicated Virtual Asset Service Provider (VASP) licensing authority exists.

III. Important Legislation
* SCER Bitcoin Legalization Proposal (Draft Proposal): A comprehensive proposal to legalize Bitcoin for trading and payments and digitize the Syrian Pound. Not yet enacted into law.
* Legislative Decree No. 5 of 2024 (Decree No. 5/2024): Enacted 2024-01-20. Prohibits dealing in currencies other than the Syrian pound, creating a technical legal risk for crypto as payment. Enforcement appears suspended.
* Legislative Decree No. 33: Governs AML/CFT compliance; applies to financial institutions and potential crypto service providers.

IV. Compliance Requirements
* Entities must adhere to AML/CFT rules under Legislative Decree No. 33.
* KYC (Know Your Customer) and suspicious transaction reporting are required.
* No specific VASP licensing regime exists yet.

V. Notable Restrictions or Limitations
* Cryptocurrency mining is explicitly illegal due to severe energy shortages.
* Legacy Decree No. 5/2024 creates a legal ambiguity for using crypto as a payment method.
* No consumer protection or deposit insurance exists for crypto assets.

VI. Recent Developments or Notes
* The analysis reflects a simulated timeline where the prior regime collapsed in late 2024.
* The primary barrier to crypto access (U.S. sanctions) was removed in May 2025.
* The 'Gray-Zone' status is driven by the gap between practical market openness (e.g., Binance entry) and the lack of de jure legalization.

Full Analysis Report

As of December 12, 2025, the regulatory status of cryptocurrency in Syria is best classified as a 'Gray-Zone'. The political landscape shifted dramatically following the collapse of the Assad regime in late 2024 and the installation of a caretaker government. This political transition has created a legal vacuum where cryptocurrency is neither explicitly legalized nor actively criminalized for retail traders. The strict prohibitions of the previous era, which treated crypto usage as a violation of foreign exchange controls, have effectively softened in practice, though they have not been formally repealed.

As of December 12, 2025, the regulatory status of cryptocurrency in Syria is best classified as a 'Gray-Zone'. The political landscape shifted dramatically following the collapse of the Assad regime in late 2024 and the installation of a caretaker government. This political transition has created a legal vacuum where cryptocurrency is neither explicitly legalized nor actively criminalized for retail traders. The strict prohibitions of the previous era, which treated crypto usage as a violation of foreign exchange controls, have effectively softened in practice, though they have not been formally repealed.

Source Evidence

Primary and secondary sources cited in this analysis

Is Crypto Legal in Syria? Regulations & Compliance in 2025 primary (analysis)

2025-09-12

"Cryptocurrency in Syria occupies a legal gray area, as there are no specific laws from the Syrian government that either permit or forbid its use."

Circular to All Banks Operating in The Syrian Arab Republic primary (regulator)

2020-06-03

"Refraining from notarizing sale contracts... unless evidence of payment... is attached to the bank account."

Crypto in Syria (2025): A Digital Lifeline Amid Economic Ruin secondary (news)

2025-06-05

"As of mid-2025: Crypto is not officially legalized, but it is not criminalized either... Mining remains illegal in Syria."

Syria Proposes Bitcoin Legislation to Stabilize Economy secondary (news)

2025-01-02

"The proposal outlines plans to legalize Bitcoin for activities such as trading and mining, while also introducing a digital version of the Syrian pound."

Cryptocurrency in the War Zone: Recent Events in Syria secondary (analysis)

2024-12-12

"Taking an official position on digital assets is not likely to emerge as a top priority in the near-term."