When a payment involves Iran, businesses may hear that the money will “go through an exchange house” rather than a bank. The Persian word is *sarrafi*. An exchange house might be a licensed currency business, a bank-affiliated exchange company, a foreign business with Iranian links, or an informal operator. These are different types of counterparties and can carry different legal, sanctions and banking risks.
This guide explains how exchange houses in Iran are regulated, why Iran-related payments receive heightened scrutiny, and what to check before a payment is made. It is general information, not legal advice. The rules and sanctions lists can change; check current requirements with qualified counsel and your bank.
What is an Iranian exchange house?
An exchange house, or sarrafi, buys and sells foreign currency and may provide other currency services. “Exchange house” describes a type of business. It does not, by itself, show that the business is licensed, supervised, acceptable to your bank or suitable for a particular payment.
Exchange houses also operate outside Iran, including in financial centres that serve customers with Iranian connections. For an overseas business, check the entity’s legal identity and authorisation in every jurisdiction where it operates. Do not assume that a licence in one country covers activities in another.
How are exchange houses regulated in Iran?
The Central Bank of Iran (CBI) regulates currency exchange businesses in Iran. Public reporting over the years has described features of the licensing and supervisory framework, including:
- Licensing for currency exchange activity, with the CBI publishing information about authorised businesses.
- Different activity categories, with permissions that may depend on the licence and CBI conditions.
- Capital requirements and guarantees that may vary by category or location.
- Supervision through reporting, monitoring and inspections.
- Limits on the purposes for which currency can be sold, which may change over time.
- Enforcement against some unlicensed operators.
Some public descriptions of these requirements are several years old. Categories, licence conditions and authorised-entity lists can change. Confirm the current licence and scope directly with the CBI or through Iranian counsel. A licence is evidence of authorisation for specified activities; it is not a sanctions clearance or a promise that a foreign bank will process a payment.
Why do Iran-related payments through exchange houses receive scrutiny?
The risk comes from the transaction, the parties and the payment route. It does not mean that every exchange house is sanctioned or that every payment involving one is prohibited.
The Financial Action Task Force (FATF) listed Iran as a high-risk jurisdiction subject to a call for action on 30 October 2026 and urged jurisdictions to apply countermeasures. The FATF also describes risk-based limits on financial relationships and transactions involving Iran. This is a jurisdiction-level assessment; it does not designate every Iranian exchange house. Each business must understand the rules that apply to it and its transaction.
U.S. Treasury actions in 2026 designated particular Iranian exchange houses and associated parties. The actions show why compliance teams should identify the actual exchange house, its owners and affiliates, and the counterparties behind a payment. They do not establish that all exchange houses engage in sanctions evasion.
An earlier OFAC advisory described examples in which third-country exchange houses or trading companies moved Iran-related funds while omitting Iranian parties or addresses from payment information. The advisory cautioned that it was not suggesting all third-country exchange houses were facilitating illicit finance. Clear and complete payment details are therefore an important part of due diligence.
Your bank may also apply its own restrictions or decline to process a payment, even where a party says it is licensed. Approval by a payment intermediary does not replace your own legal review or your bank’s decision.
What should you check before a payment involves an exchange house?
- **Confirm the legal basis.** Ask qualified counsel whether the transaction is permitted for you, considering your location, the goods or services, the parties and the payment route.
- **Identify the exchange house.** Obtain its full legal name, registration details, address, directors and the entity that will actually handle the funds.
- **Verify its authorisation.** Check the licence and permitted activities directly with the relevant regulator or through counsel. Do not rely only on a certificate supplied by the business.
- **Understand ownership and control.** Identify owners, controlling persons, directors and known affiliates, including entities in other countries.
- **Screen the parties.** Check the exchange house, its owners, directors, affiliates, payer, payee and relevant banks against the sanctions lists that apply to you. Use Persian names and reasonable transliteration variants.
- **Ask about compliance controls.** Understand how the exchange house identifies customers, screens parties and monitors transactions. Assess the answer against your own requirements.
- **Map the payment route.** Confirm the source of funds, destination, currency, banks and countries involved, and why this route is being used.
- **Match the payment to the trade.** The payer, payee, amount, currency and timing should be consistent with the contract, invoice and shipping documents. Payment records should accurately identify the parties and transaction.
- **Talk to your bank before payment.** Provide the full route and transaction details and ask what information or approvals it requires.
If key details are missing or do not match, pause the payment and resolve the issue with your legal and compliance advisers before proceeding. Do not hide or alter the identity of a party to get a payment through a bank.
How Iranlook can help
Iranlook prepares English-language reports on Iranian companies using available company information and local records. A Company Report can help you review the recorded identity, history and named officers of an Iranian company involved in a transaction, including a company that presents itself as an exchange business, where relevant information is available.
Iranlook does not confirm whether an exchange house currently holds a CBI licence. Verify licence status directly with the regulator or through counsel. Company reports also do not replace sanctions screening, legal advice or a bank’s transaction decision.
Frequently asked questions
Does a CBI licence mean an exchange house is safe for every international payment?
No. A licence relates to authorisation for specified activities under Iranian rules. It does not confirm that the business or transaction is acceptable under the laws and sanctions rules that apply to you, or that your bank will process the payment.
Is every exchange house involved in Iran-related trade sanctioned?
No. The term “exchange house” does not mean an entity is sanctioned. Screen the specific business, its owners and affiliates, the other parties and the payment route against the lists and rules relevant to your transaction.
What is the most important check before using an exchange house?
Establish who will handle the funds and verify the transaction’s legal basis, the exchange house’s authorisation, the parties’ sanctions status and the complete payment route before money moves.
Official sources
- FATF, “High-Risk Jurisdictions subject to a Call for Action,” 30 October 2026: https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-october-2026.html
- U.S. Treasury, OFAC, “Economic Fury Targets Iranian Shadow Banking Networks Moving Billions in Foreign Currency,” 1 May 2026: https://home.treasury.gov/news/press-releases/sb0483
- U.S. Treasury, OFAC, “Advisory on the Use of Exchange Houses and Trading Companies to Evade U.S. Economic Sanctions Against Iran,” 10 January 2013: https://ofac.treasury.gov/system/files/126/20130110_iran_advisory_exchange_house.pdf