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 U.S. blockchain researcher Chainalysis. Nobitex offers guidance on its website on how to skirt sanctions.
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 U.S. 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 U.S. prohibitions on doing business with Iran, lawyers and trade-sanctions experts said.
In July, Reuters 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 Reuters 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 U.S. company, unlike other platforms that have exposure to these same U.S. 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 by Reuters 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 told Reuters 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 U.S.-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 U.S. 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.
Reuters obtained the Tron figures, along with further datasets covering the other crypto tokens, from three firms with access to Chainalysis' Reactor investigation software. Reuters cross-checked each company's figures. A fourth firm also confirmed some of the figures on direct transfers based on a separate dataset compiled using different software.
Reuters is making available here 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 U.S. Justice Department investigation is whether Binance violated U.S. 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 U.S. 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 Iranian transactions documented by Reuters put Binance at risk of U.S. "secondary" sanctions, designed to prevent non-U.S. 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 U.S. financial system.
Binance could also be exposed to direct "primary" sanctions if the company has what the U.S. Treasury Department calls a "nexus to the United States," the lawyers and experts said. Such links can include any U.S.-incorporated entities, or transactions processed through the U.S. 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 U.S. authorities for criminal sanctions violations that included moving around $240 million via U.S. financial institutions for Iranian customers. Standard Chartered accepted responsibility for the violations. French bank BNP Paribas in 2014 agreed to plead guilty to violating U.S. 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 U.S. 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." Reuters reported in October that he in fact controlled the U.S. exchange and directed its management from abroad. A Binance adviser, in a message to executives in 2018, described the U.S. 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 by Reuters 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.
U.S. 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 Reuters' 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 U.S. rules governing digital asset exchanges" and only permits trading by entities that have completed a "rigorous screening process," the spokesperson said.
