US FinCEN advisory on Iran’s “illicit and malign activities”

Yesterday, the US Financial Crimes Enforcement Network (FinCEN) issued an advisory to help U.S. financial institutions detect and report potentially illicit transactions related to Iran and to help foreign financial institutions “understand the obligations of their U.S. correspondents, to avoid exposure to U.S. sanctions, and to address the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) risks that Iranian activity poses to the international financial system”.

The US Treasury press release says that following the full re-imposition on 5 November 2018 of sanctions lifted under the Joint Comprehensive Plan of Action (JCPOA), FinCEN “expects that Iranian financial institutions, the Iranian regime, and its officials will increase their efforts to evade U.S. sanctions to fund malign activities and secure hard currency for the Government of Iran. Treasury and the U.S. Government are interested in information related to the Iranian regime’s efforts outlined in this advisory, as well as information pertaining to how the Iranian regime or Iranian entities subject to sanctions, including the CBI, otherwise evade the sanctions and access the U.S. financial system.”

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About Michael O'Kane

Michael O'Kane

Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...

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