Crypto giant Binance has processed Iranian transactions with a value of $8 billion since 2018 despite US sanctions intended to cut Iran off from the global financial system, blockchain data show.
Almost all the funds, some $7.8 billion, flowed between Binance and Iran's largest crypto exchange, Nobitex, according to a review of data from leading US blockchain researcher Chainalysis. Nobitex offers guidance on its website on how to skirt sanctions, according to Reuters.
Three-quarters of the Iranian funds that passed through Binance were in a relatively low-profile cryptocurrency called Tron that gives users an option to conceal their identities. In a blog post last year, Nobitex encouraged clients to use Tron - a mid-tier token - to trade anonymously without "endangering assets due to sanctions."
The scale of Binance's Iranian crypto flows – and the fact that they are continuing – has not been previously reported.
The new findings come as the US Justice Department is pursuing an investigation into possible violations of money-laundering rules by Binance, which dominates the $1 trillion crypto industry, with over 120 million users. The transactions put the company at risk of falling afoul of US prohibitions on doing business with Iran, lawyers and trade-sanctions experts said.
In July, it was revealed that Binance continued to serve clients in Iran and that the exchange's popularity in the Islamic republic was known inside the company. It was one of a series of investigations into Binance's troubled history with financial regulatory compliance. The day of that article's publication, Binance said in a blog post that it follows international sanctions rules on Iran and blocks access to the platform to anyone based there. The exchange's billionaire founder, Changpeng Zhao, tweeted: "Binance banned Iranian users after sanctions, 7 got missed/found a workaround, they were banned later anyways."
Binance didn't answer detailed questions about the new transactions uncovered by Reuters. In a statement, spokesperson Patrick Hillmann said, "Binance.com is not a US company, unlike other platforms that have exposure to these same US sanctioned entities. However, we have taken proactive steps to limit our exposure to the Iranian marketplace," working with industry partners and internal tools.
Binance declines to give details of the location or the entity behind its Binance.com exchange.
Nobitex didn't respond to questions for this article. Nor did the Tron Network, based in the British Virgin Islands, and its founder Justin Sun.
In August 2021, Binance announced that customers would no longer be able to open accounts and use its services without identification. But since then, the exchange has processed almost $1.05 billion in trades directly from Nobitex and other Iranian exchanges, according to the Chainalysis data, which runs to November of this year. Since Zhao's tweet in July, Binance has processed around $80 million in Iranian trades.
Hillmann said in the Binance statement that the company requires full "Know Your Customer" checks for all users "and residents of Iran are prohibited from opening or maintaining an account. We are continually updating processes and technology as we learn about new risks and potential exposures. As a result of these efforts, including real-time transaction monitoring in coordination with external vendors, between June of 2021 and November of 2022, Binance's exposure to Iranian-linked entities has seen an exponential decline."
The data reviewed show that in total some $2.95 billion in crypto moved directly between Iranian exchanges and Binance since 2018.
A further $5 billion in crypto moved between Iranian exchanges and Binance through layers of intermediaries, the data also reveal. Regulators say such "indirect" flows should be a red flag to crypto exchanges - an indicator of possible money laundering and sanctions evasion. Crypto users seeking to cover their tracks often use sophisticated techniques to create complex chains of crypto transfers.
Nobitex advises its 4 million customers on its website to avoid "the direct transfer" of crypto between Iranian and foreign crypto platforms to "maintain security."
Binance spokesperson Hillmann said in June, in relation to the exchange's indirect exposure to illicit funds, that "what's important to note is not where the funds come from - as crypto deposits cannot be blocked - but what we do after the funds are deposited." He said Binance uses transaction monitoring and risk assessments to "ensure that any illegal funds are tracked, frozen, recovered and/or returned to their rightful owner."
In addition to the Tron token, the remainder of the Iranian transactions were in major cryptocurrencies bitcoin, ether, tether and XRP, and a smaller token, litecoin.
Binance is the biggest market for trading Tron, according to industry data. Some other major exchanges, including US-regulated Coinbase and Gemini, do not list the token.
Until recently, Tron has largely flown under the radar of cryptocurrency trackers. Market leader Chainalysis, used by US government agencies, only began fully supporting the tracing of Tron this May, according to an email Chainalysis sent to a client.
The Tron dataset details over 1.15 million direct transfers between Binance and Nobitex since April 2020, when the first Tron flows were recorded. The data include wallet addresses and a unique identification number for each transaction.
The Tron figures was obtained, along with further datasets covering the other crypto tokens, from three firms with access to Chainalysis' Reactor investigation software. Each company's figures were cross-checked. A fourth firm also confirmed some of the figures on direct transfers based on a separate dataset compiled using different software.
Here is the data for direct transactions since August 20, 2021, amounting to around $1 billion.
The total volume of Iranian transactions flowing through Binance is far greater than through any other exchange, the data show. After Binance, the next most popular exchange for Nobitex users since 2018 was Seychelles-based KuCoin, which processed $820 million in direct and indirect transactions.
KuCoin and six other Iranian exchanges in the dataset– CoinNik Market, Iranicard, Rabex, Wallex, Sarmayex and Tether Land – did not respond to requests for comment.
SANCTIONS RISK
Binance has grown explosively since its launch in 2017. The company extended its reach from crypto last month by investing $500 million in Tesla boss Elon Musk's buyout of Twitter.
The main focus of the US Justice Department investigation is whether Binance violated US anti-money laundering laws. As part of the case, ongoing since 2018, the department is also investigating Binance for possible criminal sanctions violations in connection with Iran, three people with knowledge of the probe said. In late 2020, the department sought records from Binance on its compliance programme, including any documents related to the transfer of crypto funds for people or entities in countries including Iran.
The Justice Department declined to comment.
The US government reimposed sanctions in 2018 on Iran that had been suspended three years earlier as part of Iran's nuclear deal with world powers. The West and the United Nations have targeted Tehran since 1979 with sanctions over its nuclear programme, along with alleged human rights violations and support for terrorism.
Six lawyers and sanctions experts said the documented Iranian transactions put Binance at risk of US "secondary" sanctions, designed to prevent non-US firms from doing business with sanctioned entities or helping Iranians evade the American trade embargo. Secondary sanctions can choke off a company's access to the US financial system.
Binance could also be exposed to direct "primary" sanctions if the company has what the US Treasury Department calls a "nexus to the United States," the lawyers and experts said. Such links can include any US-incorporated entities, or transactions processed through the US financial system or using the dollar, they said. Treasury didn't respond to a request for comment.
In 2019, Britain's Standard Chartered agreed to pay almost $930 million to US authorities for criminal sanctions violations that included moving around $240 million via US financial institutions for Iranian customers. Standard Chartered accepted responsibility for the violations. French bank BNP Paribas in 2014 agreed to plead guilty to violating US sanctions on countries including Iran and to pay $8.9 billion. Both banks committed to improving their controls.
Binance says it does not accept customers in the United States. American clients are instead directed to a separate exchange called Binance.US, run by a US company which since 2019 has been registered with the Treasury as a money-service business.
Binance CEO Zhao has described Binance.US as a "fully independent entity." He in fact controlled the US exchange and directed its management from abroad, according to reports published in October. A Binance adviser, in a message to executives in 2018, described the US operation as a "de facto subsidiary."
In a blog post after that article, Zhao reaffirmed that Binance.US "operates independently from Binance.com."
The vast majority of the $8 billion in Iranian crypto transactions identified involved the main Binance exchange. But Binance.US also processed crypto transactions worth $1.5 million from Iranian exchanges Nobitex, Wallex and Tether Land, the Chainalysis data show.
US entities that violate the Iran sanctions can face criminal fines of up to $1 million per violation. People involved can face jail terms of up to 20 years. This October, the Treasury fined Seattle-based crypto exchange Bittrex $24 million for violating sanctions on Iran and other countries by processing crypto transactions worth over $260 million. Bittrex said at the time it was "pleased to have fully resolved" the matter.
Contacted for this article, a Binance.US spokesperson said the figures for its transactions with the Iranian exchanges were not accurate and that including "direct as well as indirect transactional data from Chainalysis both conflates and inflates the volume you cite." The spokesperson didn't provide an alternative figure.
Binance.US "adheres to all applicable US rules governing digital asset exchanges" and only permits trading by entities that have completed a "rigorous screening process," the spokesperson said.
Nobitex and the other Iranian crypto exchanges haven't been sanctioned by the United States. The investigation did not find evidence that sanctioned Iranian individuals, companies or organisations used Binance or Binance.US.
"THE BEST OPTION"
Nobitex, the largest Iranian exchange, launched in 2017. Its co-founder and CEO, Amirhosein Rad, did a doctorate in philosophy and chemical engineering at Iran's Sharif University of Technology, his LinkedIn profile shows. Rad didn't comment for this article.
Nobitex's aim, stated on its LinkedIn page earlier this year, is to allow Iranians to invest in crypto despite "the shadow of sanctions." As sanctions have hit Iran's ability to do business with the outside world, crypto has grown popular there for cross-border commerce. The exchange said it serves as a "safe bridge between 3.5 million Iranians and the world of cryptocurrencies."
Nobitex said in its 2021 annual report that it processes 70% of Iranian crypto transactions. The exchange has recommended that its clients use Binance in multiple posts on its website and social media channels, as recently as this year.
Nobitex users began moving bitcoin through Binance in April 2018, the Chainalysis data show.
In a trading guide on Nobitex's website, first published in 2019 and updated this October, Nobitex advised users to open accounts to convert their Iranian rials into crypto and then make transfers to a foreign exchange such as Binance, which it called the "most reliable." Subsequent posts in 2020 said that "for us Iranians, Binance is still the best option" and that Binance "causes fewer problems for Iranian users."
Noting the risk posed by US sanctions, Nobitex's public terms of use recommend customers avoid the "direct transfer" of crypto from Nobitex to Binance and instead create multiple digital wallets to move funds in separate stages.
The volume of Tron transactions between Nobitex and Binance surged from August 2020, the Chainalysis data showed.
That same month, Tron's founder, Sun, said on Twitter the digital coin had enabled a new feature that allowed traders to mask their identities. Sun wrote that the feature, known as zk-SNARK, would "protect user data with the strongest privacy protection in the industry."
An article published in a Justice Department journal last year said the feature allows the development of "anonymity enhanced cryptocurrencies" that attract criminals "like sharks to chum" as they "seek out privacy to conceal their conduct."
Nobitex recommended that users open digital wallets with Binance to buy Tron due to its "high security." A Nobitex blog post in July 2021 said zk-SNARK was key to keeping those sending and receiving crypto "hidden."
Nobitex customers remained able to use Binance to trade Tron and other crypto tokens after Binance tightened its checks on clients on August 20, 2021, according to the data. Binance processed direct transactions from Nobitex totalling over $1 billion between that date and November of this year, far outstripping any other international exchange, it showed. As recently as this October, $20 million in Tron flowed directly between Binance and Nobitex, the data show.
Iranians sanctioned by the US Treasury for cyberattacks and ransomware activity have used Nobitex, a Chainalysis report in September said. Between 2015 and 2022, the digital wallets of sanctioned Iranians received over $230,000 in bitcoin ransomware funds, Chainalysis said, with most of the crypto sent to Nobitex.
The Treasury said the same month that the sanctioned Iranians were all affiliated with the Islamic Revolutionary Guard Corps, a powerful faction that controls a business empire as well as elite armed and intelligence forces in Iran. Iranian authorities did not respond to a request for comment. The Iranian Foreign Ministry has called US sanctions "unilateral, illegal and cruel."