Financial Crime World

Financial Institutions Urged to Monitor for Malign Activity in SAR Filings

The Financial Crimes Enforcement Network (FinCEN) has issued an advisory warning financial institutions to be vigilant against suspicious activity that may indicate malign Iranian-related activity, aimed at combating illicit financial activities.

Warning Signs of Malign Activity

Iran and its affiliated entities have been known to use several tactics to evade U.S. sanctions, including:

  • Hiding vessel registration and flag credentials at ports of call and canal entrances
  • Using precious metals such as gold to circumvent sanctions
  • Exploiting virtual currency platforms to facilitate illegal transactions

Conduct Due Diligence

Financial institutions are advised to conduct thorough due diligence on all transactions, including those involving virtual currencies. This includes:

  • Reviewing blockchain ledgers for activity that may originate or terminate in Iran
  • Being aware of new virtual currency businesses that may operate in Iran with little notice or footprint

Reporting Suspicious Activity

Institutions are required to report any suspicious activities that appear to be related to malign Iranian-related activity in their Suspicious Activity Reports (SARs). Failure to do so could result in serious consequences, including fines and reputational damage.

Key Takeaways:

  • Financial institutions should be aware of tactics used by Iran to evade U.S. sanctions
  • Conduct thorough due diligence on all transactions, including those involving virtual currencies
  • Review blockchain ledgers for activity that may originate or terminate in Iran
  • Be aware of new virtual currency businesses that may operate in Iran with little notice or footprint
  • Report any suspicious activities that appear to be related to malign Iranian-related activity in SARs

The Importance of Vigilance

The advisory is a reminder of the ongoing threat posed by Iran’s illicit financial activities and the importance of vigilance on the part of financial institutions. By working together to combat these threats, we can help prevent illegal transactions and protect the integrity of the global financial system.