Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System

October 11, 2018

The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to help U.S. financial institutions (particularly banks; money services businesses (MSBs), such as virtual currency administrators and exchangers; and dealers in precious metals, stones, and jewels) better detect potentially illicit transactions related to the Islamic Republic of Iran (Iran). This advisory will also help foreign financial institutions better understand the obligations of their U.S. correspondents, avoid exposure to U.S. sanctions, and address the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) risks that Iranian activity poses to the international financial system.

The Iranian regime has long used front and shell companies to exploit financial systems around the world to generate revenues and transfer funds in support of malign conduct, which includes support to terrorist groups, ballistic missile development, human rights abuses, support to the Syrian regime, and other destabilizing actions targeted by U.S. sanctions.

This advisory highlights the Iranian regime’s exploitation of financial institutions worldwide, and describes a number of typologies used by the regime to illicitly access the international financial system and obscure and further its malign activity. It also provides red flags that may assist financial institutions in identifying these methods. Additionally, this advisory is intended to assist financial institutions in light of the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA) and the re-imposition of U.S. sanctions previously lifted under the JCPOA following the 90- and 180-day wind-down periods for certain activities, while also reminding financial institutions of regulatory obligations under the Bank Secrecy Act (BSA) and the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).


Read the full advisory below.