The Community Suggested Amendments on CBI's Crypto Regulations
Hamidreza Asgari | 2019-03-08

The Community Suggested Amendments on CBI’s Crypto Regulations

An amendment to the Central Bank of Iran (CBI) regulations draft on cryptocurrency has been offered to CBI by a group of experts and activists in cryptocurrency ecosystem in Iran.

After the regulations draft on cryptocurrency issued by CBI on Jan 28, 2019, it caused a couple of objections and discussions in crypto community. As the draft issued, CBI considered one-month deadline to get any feedback or suggestion to make it better.

Hamed Salehi, a Bitcoin and blockchain researcher and active member of crypto community, who sent the content of this amendment offer for the first time to CoinIran, attempted several times to organize a number of discussion sessions and appointment with community’s experts within the deadline.

As the document stated, it is the result of agreement in discussion meetings of about 37 experts in economy, blockchain technology, businesspersons, investors, researchers and activists of crypto community in Iran. They emphasized that this document is not to challenge with the government, but it contains critiques to the draft and a number of offers for better regulation toward a correct direction.


Iran’s crypto community experts

These experts believe that some definitions in the draft have serious legitimate concerns and could possibly put people’s businesses in jeopardy. They also suggested that CBI to postpone the Money and Credit Council meeting at least four months on passing the regulation in order to have more time to get more suggestions and amendment offers.

The content criticizes the regulation draft in below categories:


The regulations are not fully based on money and financial laws or is in low compliance with those laws.


There are some paradoxes in the content which may cause making wrong decision for businesses.


Some of definitions that are technically and fundamentally incorrect shows they did not deeply study on cryptocurrency and blockchain technology.


Regarding to other contents issued by lawmakers, the structure of the content has inconsistencies in defining terminologies and conditions.

Legitimate concerns:

Experts believe passing a draft with such a structure could possibly put people and their businesses in trouble.


Because of the nature of blockchain technology, controlling and observing some regulations in the draft are not practical and they need technical solutions.

Consumer rights protection:

The consumer rights and the risks belong to them did not explained and CBI responsibility is limited to warn only and it is not enough for consumers.

Business facility:

By limiting and banning use of cryptocurrencies, businesses cannot develop and continue in this industry.


At the end, the document delivers the amendment suggestions in the following clauses:

  • postponing the Money and Credit Council meeting at least four months on passing the regulation in order to have more time in getting more suggestions and amendment offers from experts of ecosystem.
  • CBI with a schedule planning on its policies, let investors and business managers make correct decision.
  • CBI to organize an official relationship between lawmakers and cryptocurrency and blockchain ecosystem for best use of this opportunity.
  • CBI to amend conflicting legitimate definitions by taking the ecosystem experts consultant (if they insist to pass the draft).
  • CBI to use correct form of definitions and terminologies based on technical documents of cryptocurrency and blockchain technology.
  • CBI to organize a committee including experts of ecosystem and the CBI’s experts to redefine the content and structure of the draft in order to avoid different interpretations.