PRINT
1257. Are non-U.S. persons exposed to sanctions risk for dealing with Iran-based digital asset exchanges Nobitex, Wallex, Bitpin, and Ramzinex following their June 2, 2026 designation?
Yes. OFAC's June 2, 2026 designation of Iran-based digital asset exchanges Nobitex, Wallex, Bitpin, and Ramzinex pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who engage in certain transactions with these exchanges also risk exposure to sanctions under E.O. 13902. For example, pursuant to E.O. 13902, OFAC has authority to:
* Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Nobitex, Wallex, Bitpin, and Ramzinex; or Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of Nobitex, Wallex, Bitpin, and Ramzinex.
In addition, foreign financial institutions may be exposed to mandatory statutory sanctions for engaging in significant financial transactions with Nobitex, Wallex, Bitpin, and Ramzinex, designated Iranian financial institutions, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.
Date Released
June 2, 2026
See related designation notice at https://home.treasury.gov/news/press-releases/sb0519. The purpose of the FAQ appears to be signaling that there is some intent to impose secondary sanctions on non-U.S. persons for dealings involving the various digital asset exchanges sanctioned (including pursuant to the standard “material support” provision. Note that OFAC regards these entities as “Iranian financial institutions.” Accordingly, transactions involving these entities, which were blocked pursuant to the ITSR (560.211) and EO 13902, can qualify for Iran GL L (covering “transactions and activities that are authorized, exempt, or otherwise not prohibited under the [ITSR] involving Iranian financial institutions blocked pursuant to Executive Order (E.O.) 13902…including transactions and activities authorized by a general or specific license issued pursuant to the ITSR”). Consistent with FAQ # 7, transactions qualifying for GL L are presumptively not “sanctionable”.