The Financial Crimes Enforcement Network, the U.S. Treasury’s financial watchdog, on Thursday released a major warning about the dangers of Iranian abuse of the global trade and finance systems. Despite the alarming tone of the report, the specifics are fuzzy and largely theoretical, ultimately revealing more about regulators than about their supposed targets.
According to FinCEN, Iran as a whole has generated at least $3.8 million of bitcoin transactions per year since 2013. But that’s a rounding error on global cryptocurrency movements that now total roughly $200 million per day, and it’s a minuscule percentage of Iran’s GDP of more than $390 billion.
While FinCEN devotes pages to the idea that Iran will use crypto to break sanctions, the report doesn’t specifically claim that the Iranian government has done this. It simply warns that cryptocurrency “may provide potential avenues for individuals and entities to evade sanctions.” While offering no specific evidence of such crime, FinCEN advises exchanges to be cautious about dealing with customers using Iranian email addresses or logging in from Iran. (FinCEN did not reply to BREAKER’s request for comment.)
There is growing concern that marginalized governments will increasingly use crypto to work around international sanctions. In the two most notable cases, North Korean hackers tried extorting bitcoin using the WannaCry malware, and Venezuela tried raising funds by issuing an oil-backed cryptocurrency called the Petro. “Tried” is definitely the operative term, though—both of those efforts seem to have been largely ineffective. In a finding specific to Iran, researchers recently showed that terrorists don’t actually use cryptocurrency to fund their activities very often. (Hilariously, it’s because crypto is too hard to use.)
Furthermore, it’s not as if Iran desperately needs cryptocurrency to defy sanctions. Its government routinely uses shell companies and other techniques to both ship goods and send and receive international payments. That’s little surprise: As we’ve recently reported, mainstream banks have been repeatedly caught moving and hiding money for international drug lords, Russian kleptocrats, and old-fashioned tax-evaders.
So if there’s little solid proof in this report, why does FinCEN issue such a stern warning about illicit Iranian crypto? FinCEN may know more than it’s disclosing in this brief—maybe Iran really is moving a lot of money through cryptocurrency exchanges. But it’s also likely that the warning is driven by a deeper fear of cryptocurrency eroding first-world governments’ control (imperfect as it is) over a global financial system. Using crypto to avoid financial censorship by countries like the U.S. hasn’t been clearly observed, but it’s a compelling proposal—especially once largely untraceable currencies like Monero are considered.
Why would FinCEN release such an alarmist warning now? It might be because Iran’s shady dealings, via crypto or other means, will likely get more intense very soon. On November 4, U.S. restrictions on Iranian oil exports are set to get much tighter. Those restrictions will make it even harder for Iranian businesses to get their hands on foreign currencies, which will in turn restrain international trade even further. Iran’s currency, the rial, has also lost as much as three-fourths of its value versus other world currencies this year, also thanks to sanctions anxiety. All of that, ironically, will make cryptocurrency much more attractive for everyday Iranians, and perhaps even the government.
Eventually Iran, or another outcast nation, will actually figure out how to use it.