U.S. Senate Investigation: USDT is a key liquidity channel for Iran's shadow banking, Gulf VASP faces higher sanction risks

A report from the U.S. Senate Permanent Subcommittee on Investigations (PSI) identifies stablecoins, particularly USDT, as a key liquidity channel supporting Iran's shadow banking system. Licensed virtual asset service providers (VASP) in the Gulf Cooperation Council (GCC) region face heightened sanctions compliance pressure and need to enhance wallet ownership identification and counterparty assessment.

Soham Jethani, a partner at the law firm Septten, stated that merchants settling crypto assets into local fiat currency do not necessarily avoid sanctions risks. Liability may involve designated entities, the provision of funds or economic resources, and asset handling within the transaction chain, potentially arising before the final settlement by banks. Jethani pointed out that the name of the stablecoin or the currency in which it is priced does not determine legal ownership; specific rights depend on contractual arrangements and actual payment processes.

Globally circulating stablecoins may also pose secondary sanctions risks, as indirect or historical wallet associations do not automatically constitute violations and must be assessed in conjunction with applicable regulations, transaction participants, and specific facts. In regulated markets like the UAE, licensed exchange wallets are continuously monitored, and related funds can be frozen before consumption settlements, with merchants also required to complete KYC. Regulated VASPs handling deposits and withdrawals bear the responsibility for counterparty and sanctions risk assessment and corresponding controls.