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Financial Crimes Enforcement Network

Advisory

FIN-2008-A002
Issued: March 20, 2008
Subject: Guidance to Financial Institutions on the Continuing Money Laundering Threat Involving Illicit Iranian Activity


The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to supplement information previously provided1on serious deficiencies present in the anti-money laundering systems of the Islamic Republic of Iran. The Financial Action Task Force (FATF) stated in October 2007 that Iranís lack of a comprehensive anti-money laundering and combating the financing of terrorism (AML/CFT) regime represents a significant vulnerability in the international financial system. In response to the FATF statement, Iran passed its first AML law in February 2008. The FATF, however, reiterated its concern about continuing deficiencies in Iranís AML/CFT system in a statement on February 28, 2008. Further, on March 3, 2008, the United Nations Security Council passed Resolution 1803 (UNSCR 1803), calling on all states to exercise vigilance over activities of financial institutions in their territories with all banks domiciled in Iran and their branches and subsidiaries abroad. The FATF statement, combined with the UNís specific call for vigilance, illustrates the increasing risk to the international financial system posed by the Iranian financial sector, including the Central Bank of Iran.

Iranís AML/CFT deficiencies are exacerbated by the Government of Iranís continued attempts to conduct prohibited proliferation related activity and terrorist financing. Through state-owned banks, the Government of Iran disguises its involvement in proliferation and terrorism activities through an array of deceptive practices specifically designed to evade detection. The Central Bank of Iran and Iranian commercial banks have requested that their names be removed from global transactions in order to make it more difficult for intermediary financial institutions to determine the true parties in the transaction. They have also continued to provide financial services to Iranian entities designated by the UN Security Council in its Resolutions 1737 and 1747 as entities involved in nuclear proliferation activities. The U.S. Department of the Treasury is particularly concerned that the Central Bank of Iran may be facilitating transactions for sanctioned Iranian banks.

UNSCR 1803 calls on member states to exercise vigilance over the activities of financial institutions in their territories with all banks domiciled in Iran, and their branches and subsidiaries abroad. While Bank Melli and Bank Saderat were specifically noted, the United States urges all financial institutions to take into account the risk arising from the deficiencies in Iranís AML/CFT regime, as well as all applicable U.S. and international sanctions programs, with regard to any possible transactions with the following Iranian institutions:


1See "Guidance to Financial Institutions on the Increasing Money Laundering Threat Involving Illicit Iranian Activity," FIN-2007-A001, October 16, 2007.

[This list has been updated as of June 22, 2010. Please see FIN-2010-A008 at (http://www.fincen.gov/statutes_regs/guidance/html/fin-2010-a008.html)]

NAME LOCATION
AGRICULTURAL BANK (a.k.a. BANK KESHAVARZI) Tehran, Iran
AGRICULTURAL COOPERATIVE BANK OF IRAN (a.k.a. BANK TAAVON KESHAVARZI IRAN) Tehran, Iran
AGRICULTURAL DEVELOPMENT BANK OF IRAN (a.k.a. BANK JOSIAIYI KESHAHVARZI) Tehran, Iran
ARIAN BANK (a.k.a. ARYAN BANK) Kabul, Afghanistan
BANCO INTERNACIONAL DE DESARROLLO SA Caracas, Venezuela
BANK KARGOSHAEE Tehran, Iran
BANK MASKAN (a.k.a. HOUSING BANK (of Iran) Tehran, Iran
BANK MELLAT Tehran, Iran
BANK MELLAT Seoul, South Korea
BANK MELLAT Ankara, Istanbul, Izmir, Turkey
BANK MELLI IRAN Tehran, Iran
BANK MELLI IRAN Paris, France
BANK MELLI IRAN Hamburg, Germany
BANK MELLI IRAN Central, Hong Kong
BANK MELLI IRAN Baghdad Iraq
BANK MELLI IRAN Muscat Oman
BANK MELLI IRAN Al Ain Deira, Dubai City, Fujairah, Ras al-Khaimah, and Sharjah, United Arab Emirates
BANK MELLI IRAN ZAO Moscow Russia
BANK OF INDUSTRY AND MINE (of Iran) (a.k.a. BANK SANAD VA MADAN) Tehran, Iran
BANK REFAH (f.k.a. WORKERS WELFARE BANK, f.k.a. BANK REFAH KARGARAN) Tehran, Iran
BANK SADERAT IRAN Tehran, Iran
BANK SADERAT Paris, France
BANK SADERAT Frankfurt, Hamburg, Germany
BANK SADERAT Athens, Greece
BANK SADERAT Baalbak, Beirut, Saida, Lebanon
BANK SADERAT Muscat, Oman
BANK SADERAT Doha, Qatar
BANK SADERAT Ashgabat, Turkmenistan
BANK SADERAT Abu Dhabi, Ajman, Al Ain, Dubai City, Sharjah, United Arab Emirates
BANK SADERAT PLC London, United Kingdom
BANK SADERAT TASHKENT Tashkent, Uzbekistan
BANK SEPAH Tehran, Iran
BANK SEPAH Paris, France
BANK SEPAH Frankfurt, Germany
BANK SEPAH Rome, Italy
BANK SEPAH INTERNATIONAL PLC London, United Kingdom
BANK TEJARAT Tehran, Iran
BANK TEJARAT Paris, France
BANK TEJARAT Dusanbe, Tajikistan
THE CENTRAL BANK OF IRAN (a.k.a. BANK MARKAZI JOMHOURI ISLAMI IRAN) Tehran, Iran
EUROPAEISCH-IRANISCHE HANDELSBANK AG (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG) Hamburg, Germany
EUROPAEISCH-IRANISCHE HANDELSBANK AG (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG) Tehran, Iran
EXPORT DEVELOPMENT BANK OF IRAN (a.k.a. BANK TOWSEH SADERAT IRAN) Tehran, Iran
FUTURE BANK B.S.C. Manama, Bahrain
IRAN OVERSEAS INVESTMENT BANK PLC (a.k.a. IRAN OVERSEAS INVESTMENT CORPORATION LIMITED) London, United Kingdom
KARGOZARI BANK TEJARAT Tehran, Iran
MELLAT BANK DB AOZT (a.k.a. MELLAT BANK S/B CJSC) Yerevan, Armenia
MELLAT BANK S/B CJSC (a.k.a. MELLAT BANK DB AOZT) Yerevan, Armenia
MELLI BANK PLC. London, United Kingdom
PERSIA INTERNATIONAL BANK PLC. London, United Kingdom
PERSIA INTERNATIONAL BANK PLC. Dubai City, United Arab Emirates

Privately Owned Iranian Financial Institutions

NAME LOCATION
BANK PASARGAD Tehran, Iran
EN BANK PJSC (a.k.a. EGHTESAD-E-NOVIN BANK) Tehran, Iran
KARAFARIN BANK Tehran, Iran
PARSIAN BANK Tehran, Iran
POST BANK OF IRAN Tehran, Iran
SAMAN BANK CORPORATION Tehran, Iran
BANK SARMAYE Tehran, Iran

Financial institutions also are reminded of the existing U.S. sanctions that are administered by the Department of the Treasuryís Office of Foreign Assets Control (OFAC) with respect to Iran and the Government of Iran, including but not limited to Iranian Government-owned banks, as well as other sanctions imposed on Iranian entities that have been linked to terrorist activity and the proliferation of weapons of mass destruction. Information about these sanctions is available on OFAC's website at http://www.treasury.gov/offices/enforcement/ofac/.





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