WASHINGTON—Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024, based on reporting from U.S. financial institutions. This FTA, which supports President Trump’s maximum pressure campaign on Iran, will help to ensure financial institutions are tracking and countering the threat posed by Tehran’s shadow banking activity.
Tehran relies on shadow banking networks of Iran-based exchange houses and foreign companies to evade sanctions, sell oil and other commodities abroad, launder money, sustain its regional terrorist proxies, and fund its military and weapons programs. Iranian shadow banking networks are connected across continents—most prominently through the United Arab Emirates (UAE), Hong Kong, and Singapore—by a diverse array of Iranian front companies. This includes oil companies, shell companies, shipping companies, investment companies, and technology procurement companies, which transact billions of dollars with each other and with unrelated companies, who may be witting or unwitting counterparties.
“Identifying Iran’s complex financial lifelines and shadow networks is an essential part of cutting off the funding for their military, weapons programs, and terrorist proxies,” said FinCEN Director Andrea Gacki. “By issuing this public analysis, we hope to draw attention to Iran’s shadow banking activity and encourage financial institutions to be vigilant.”
On February 4, 2025, President Trump announced a maximum pressure campaign against Iran with the goals of denying Iran nuclear weapons and intercontinental ballistic missiles; countering its development of other weapons capabilities; neutralizing Iran’s network and campaign of regional aggression; and disrupting, degrading, and denying Iran and its terrorist proxies access to the resources that sustain their destabilizing activities.
FinCEN’s analysis is based on information pertaining to transactions that occurred before the announcement of the maximum pressure campaign and further supplements the information within FinCEN’s June Advisory on the Iranian regime’s illicit oil smuggling activities, shadow banking networks, and weapons procurement efforts. FinCEN’s analysis includes case studies and infographics to highlight its significant findings, including that:
Foreign Shell Companies Operating Outside the United States Appear to Play the Largest Role in Iranian Shadow Banking Networks
- Shell companies—which exist only on paper with no meaningful business activities—transacted approximately $5 billion in 2024.
Iran-Linked Oil Companies Transacted Billions of Dollars, Potentially for Illicit Oil Sales
- FinCEN identified dozens of foreign oil companies that appear to be Iranian front companies, including oil companies primarily based in the UAE and Singapore that transacted approximately $4 billion in 2024.
Potential Technology Procurement Companies Received Funds from Iran-Linked Entities
- Companies potentially facilitating Iranian procurement of export-controlled technology engaged in approximately $413 million in transactions in 2024.
FinCEN’s FTA is available online at: https://www.fincen.gov/system/files/2025-10/FTA-Iranian-Shadow-Banking.pdf
Questions or comments regarding the contents of the FTA should be addressed to the FinCEN Regulatory Support Section by submitting an inquiry at www.fincen.gov/contact. Members of the media may contact press@FinCEN.gov.
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FinCEN periodically publishes Financial Trend Analyses describing threat pattern and trend information derived from Bank Secrecy Act (BSA) filings to highlight priority illicit finance risks. These analyses provide information that is relevant to a wide range of consumers, businesses, and industries; communicate the value of BSA reporting; and enhance feedback loops between government users of BSA reports and their filers. Additionally, Financial Trend Analyses fulfill FinCEN’s obligations pursuant to section 6206 of the Anti-Money Laundering Act of 2020, which requires FinCEN to periodically publish threat pattern and trend information derived from BSA filings.
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