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Cryptocurrency and Financial Crime in Iran: A Growing Concern for Global Institutions
The Financial Crimes Enforcement Network (FinCEN) has issued an advisory to help global institutions detect and report potentially illicit transactions linked to the Islamic Republic of Iran. This move aims to combat the growing threat of financial crime, which is expected to increase due to the re-imposition of US sanctions on Iran in November 2018.
Deceptive Practices Used by the Iranian Regime
The advisory highlights the deceptive practices used by the Iranian regime to evade sanctions and finance its malign activities. These practices include:
- Using front companies, fraudulent documents, exchange houses, seemingly legitimate businesses, and government officials to generate illicit revenues
- Financing terrorist activities through these means
- Utilizing virtual currency and precious metals to evade sanctions
Red Flag Indicators
The advisory warns of red flag indicators related to specific malign activities and typologies. These include:
- Use of senior officials of the Central Bank of Iran to procure hard currency and conduct transactions for the benefit of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its terrorist proxy group, Lebanese Hizballah
- Routing transactions to personal accounts rather than central bank or government-owned accounts
- Iranian abuses of virtual currency and precious metals to evade sanctions
Financial Institution Responsibilities
Financial institutions are advised to exercise appropriate due diligence when dealing with transactions involving exchange houses that may have exposure to the Iranian regime and/or designated Iranian persons. The advisory also warns of possible evasive practices involving:
- Iranian shipping companies
- Use of front and shell companies around the world in procurement networks
Filing Suspicious Activity Reports (SARs)
The advisory urges financial institutions to file SARs with FinCEN, providing all pertinent available information in the SAR form and narrative. This includes:
- Concrete examples of exchange house-related schemes
- Possible evasive practices involving Iranian shipping companies and front and shell companies around the world
Conclusion
“This advisory lays out in great detail the extent to which the Iranian regime uses deceptive practices to generate illicit revenues and finance its terrorist activities,” said Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence. “Governments, financial institutions, and companies around the world need to be on high alert to these schemes.”