Yes, almost certainly. The architecture is too efficient to be left as a one-off.
Three conditions make replication probable. First, the clean nature of the operational sequence: identify wallet, coordinate with issuer, freeze, then designate. There is no court, no statute, no contested process. Second, the speed advantage: the asset is locked before the target has notice and can move it. Third, the regulatory tailwind: once the GENIUS Act NPRM is finalised, every PPSI will be required to maintain the technical block/freeze/reject capability as a condition of operating. The architecture becomes baseline infrastructure rather than discretionary cooperation.
The strategy has in fact already been copied at the criminal-actor level for years. Tether and Circle have frozen North Korean wallets, ransomware proceeds, mixer-linked addresses and US sanctions-listed individuals. The cumulative volume runs into the billions. What Bank Markazi does is escalate the same playbook to a state actor, the central bank of Iran. The procedural template that has been quietly running against non-state targets is now operational against a sovereign.
Likely next targets fall into three categories. Russia-linked: sanctioned banks, oligarchs and state-procurement networks holding stablecoin balances. North Korea: Lazarus Group, weapons-proliferation finance, IT-worker revenue flows. Cartel finance: with Mexican cartels carrying FTO designations, the on-chain rails for fentanyl precursors and laundering proceeds are a natural fit. Each shares the two preconditions Bank Markazi met, an identifiable on-chain footprint and a cooperative issuer.
The strategy will run into limits in three places. Where there is no central issuer, the architecture cannot work because issuer-level freeze authority requires an issuer; DAI, FRAX and native crypto sit outside the model. Where the stablecoin is foreign-issued and non-cooperating, Treasury has no equivalent leverage; the Russian and Chinese state-backed stablecoin programmes in development are designed precisely around that gap. Where targets migrate to privacy chains or P2P/OTC rails, wallet identification becomes hard enough that the freeze step has nothing to attach to.
Counterparty migration is the structural countermove. Sanctioned actors will increasingly hold value in instruments the US cannot reach at issuer level and the next generation of state-backed stablecoins is being built with that reasoning visible on the face of it.
Bank Markazi is the proof of concept for state targets on a template that has been running against non-state targets for years. The next twelve to twenty-four months will produce more state-actor freezes, with Russia, North Korea and Iran-affiliated entities the most probable first wave. The hard limit sits at decentralised or foreign non-cooperating issuance, and that is where the migration pressure will concentrate.
Does the freeze/block applies to blockchain as well or only to stablecoins? Because if they apply to blockchain, technically it breaks the concept of immutability.
Good question. The freeze operates at the issuer's smart contract level, not at the blockchain level. The TRON ledger itself is unchanged. Transactions and balances remain visible and the chain's history is intact. What Tether does is invoke an administrative function in the USDT contract to prevent the listed addresses from transferring tokens. The tokens still sit in the wallet, but the issuer refuses to honour any further movement.
Native blockchain assets like BTC or ETH cannot be frozen the same way because there is no issuer to invoke. Tokenised assets with an issuer-controlled contract, such as USDT, USDC and PYUSD, can. Immutability of the ledger and immutability of the asset are different properties. The first survives. The second was never engineered into stablecoins and that is precisely what the GENIUS Act now formalises.
Do you think this strategy will be copied when the time will come against other entities?
Yes, almost certainly. The architecture is too efficient to be left as a one-off.
Three conditions make replication probable. First, the clean nature of the operational sequence: identify wallet, coordinate with issuer, freeze, then designate. There is no court, no statute, no contested process. Second, the speed advantage: the asset is locked before the target has notice and can move it. Third, the regulatory tailwind: once the GENIUS Act NPRM is finalised, every PPSI will be required to maintain the technical block/freeze/reject capability as a condition of operating. The architecture becomes baseline infrastructure rather than discretionary cooperation.
The strategy has in fact already been copied at the criminal-actor level for years. Tether and Circle have frozen North Korean wallets, ransomware proceeds, mixer-linked addresses and US sanctions-listed individuals. The cumulative volume runs into the billions. What Bank Markazi does is escalate the same playbook to a state actor, the central bank of Iran. The procedural template that has been quietly running against non-state targets is now operational against a sovereign.
Likely next targets fall into three categories. Russia-linked: sanctioned banks, oligarchs and state-procurement networks holding stablecoin balances. North Korea: Lazarus Group, weapons-proliferation finance, IT-worker revenue flows. Cartel finance: with Mexican cartels carrying FTO designations, the on-chain rails for fentanyl precursors and laundering proceeds are a natural fit. Each shares the two preconditions Bank Markazi met, an identifiable on-chain footprint and a cooperative issuer.
The strategy will run into limits in three places. Where there is no central issuer, the architecture cannot work because issuer-level freeze authority requires an issuer; DAI, FRAX and native crypto sit outside the model. Where the stablecoin is foreign-issued and non-cooperating, Treasury has no equivalent leverage; the Russian and Chinese state-backed stablecoin programmes in development are designed precisely around that gap. Where targets migrate to privacy chains or P2P/OTC rails, wallet identification becomes hard enough that the freeze step has nothing to attach to.
Counterparty migration is the structural countermove. Sanctioned actors will increasingly hold value in instruments the US cannot reach at issuer level and the next generation of state-backed stablecoins is being built with that reasoning visible on the face of it.
Bank Markazi is the proof of concept for state targets on a template that has been running against non-state targets for years. The next twelve to twenty-four months will produce more state-actor freezes, with Russia, North Korea and Iran-affiliated entities the most probable first wave. The hard limit sits at decentralised or foreign non-cooperating issuance, and that is where the migration pressure will concentrate.
Does the freeze/block applies to blockchain as well or only to stablecoins? Because if they apply to blockchain, technically it breaks the concept of immutability.
Good question. The freeze operates at the issuer's smart contract level, not at the blockchain level. The TRON ledger itself is unchanged. Transactions and balances remain visible and the chain's history is intact. What Tether does is invoke an administrative function in the USDT contract to prevent the listed addresses from transferring tokens. The tokens still sit in the wallet, but the issuer refuses to honour any further movement.
Native blockchain assets like BTC or ETH cannot be frozen the same way because there is no issuer to invoke. Tokenised assets with an issuer-controlled contract, such as USDT, USDC and PYUSD, can. Immutability of the ledger and immutability of the asset are different properties. The first survives. The second was never engineered into stablecoins and that is precisely what the GENIUS Act now formalises.