According to Cointelegraph, Iran's largest cryptocurrency exchange Nobitex — serving roughly 11 million users and recording approximately $5 billion in observed volume between 2025 and March 2026 per TRM Labs — has yet to receive an individual OFAC SDN designation despite extensive documented ties to sanctioned entities. Elliptic reported in January 2026 that Iran's central bank conducted at least $507 million in USDT purchases through a UAE broker, with funds directed primarily to Nobitex, effectively performing foreign exchange interventions outside the international banking system. The exchange's founders are linked to a prominent Iranian political and clerical family, and an early investor held ties to a company sanctioned for supplying Iranian drones to Russia. Source code leaked in June 2025 revealed built-in modules for stealth addresses, transaction batching, and compliance bypass. Analysts suggest OFAC's restraint may stem from the near-impossibility of separating state flows from the savings of millions of ordinary Iranian users — a structural problem the SDN mechanism, in its current form, has not resolved.