WASHINGTON—Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert to help financial institutions identify and stop funding streams and procurement networks supporting Iran’s Islamic Revolutionary Guard Corps (IRGC). The IRGC has engaged in terrorist activity since its inception with the full support of the Iranian regime. The Alert outlines how the IRGC facilitates and launders the proceeds of illicit oil sales by using networks of shell companies and financial facilitators. To promote detection and reporting of suspicious activity by financial institutions, the Alert provides red flags related to the IRGC’s oil smuggling, front company abuse, and use of digital assets.
“Degraded by Economic Fury, the Iranian military is desperately trying to fund its weapons programs and terrorist proxies,” said Secretary of the Treasury Scott Bessent. “Treasury will continue to deny the Islamic Revolutionary Guard Corps access to the financial networks it exploits to fund its terrorist acts. Financial institutions should be on notice that they have a responsibility to detect suspicious activity and stop it in its tracks.”
The IRGC is one of the most destabilizing forces in the Middle East and a primary supporter of terrorism in the region and beyond.
- The IRGC is the parallel organization to Iran’s regular armed forces and reports directly to Iran’s Supreme Leader. The IRGC, especially the IRGC-Qods Force, conducts covert operations abroad and supports terrorism by supplying funding, training, and weapons to proxy terrorist organizations.
- The IRGC is a U.S.-designated foreign terrorist organization (FTO), having engaged in terrorist activity since its inception with the support of the Iranian regime.
The IRGC derives profits from illicit oil sales by misrepresenting its commercial activity.
- The IRGC and its subordinate units smuggle oil to international buyers and use the proceeds to fund procurement, domestic weapons development, and terrorist activity abroad.
- To smuggle the oil, the IRGC and other Iranian actors use a “shadow fleet” of old and poorly maintained vessels that operate outside of standard maritime regulations and are often owned, managed, or leased by shipping or front companies outside of Iran.
- To further disguise its origins, Iranian oil is sometimes blended with oil from third countries or relabeled with forged documents as the product of another jurisdiction.
Proceeds from oil sales are laundered through networks of exchange houses and front companies.
- The IRGC and other Iranian regime actors rely on multi-jurisdictional “shadow banking” networks comprised of exchange houses, trading companies, and front companies to sell oil and other commodities abroad, launder the proceeds, and then procure weapons and other materiel on the international market.
- Front companies in third-country jurisdictions, usually controlled by exchange houses in Iran, are used to establish bank accounts outside of Iran through which sanctioned entities access the international banking system.
- By using front company accounts outside Iran to receive and remit payments, sanctioned entities like the IRGC are able to conduct transactions through the international financial system without repatriating funds to Iran.
IRGC front company networks are supported by a broad range of facilitators and other service providers.
- IRGC oil smuggling and shadow banking networks are bolstered by a vast web of facilitators, including money services businesses, investment companies, and trust and company service providers, which assist—wittingly and unwittingly—in orchestrating complex money laundering and sanctions evasion schemes.
- In addition, the IRGC often engages in oil smuggling and launders the proceeds in conjunction with terrorist partner and proxy groups such as Ansarallah and Lebanese Hizballah, which have their own global networks of facilitators and intermediaries.
Digital asset transactions serve as a leg of Iran’s shadow banking network.
- Digital assets function as part of a complex transactional structure designed to obfuscate Iranian involvement. Like other illicit actors, Iranian facilitators are likely to use stablecoins for this purpose, due to stablecoins’ relative liquidity, ease of settlement, and exchange rate stability.
- Iran-based digital asset service providers (DASPs) play a role in enabling Iranian digital assets activity and connectivity with the global digital assets ecosystem.
- Uneven and often inadequate regulation and supervision of digital assets across jurisdictions also enables Iranian facilitators to access digital assets through international DASPs.
Financial institutions should exercise vigilance and look for red flags. The Alert contains a full list of red flags. Examples include:
- Shipping companies with Iranian counterparties
- Efforts to disguise vessel information and ownership, or efforts to disguise oil origins
- Unusual use of exchange houses
- Unusual digital asset payments by petroleum, shipping, trading, or trust companies
- Unregistered P2P exchangers, foreign-located money services businesses, and nested digital asset service providers
Economic Fury
The Treasury Department is maintaining maximum pressure on Iran and targeting the regime’s ability to generate, move, and repatriate funds. Treasury is aggressively advancing Economic Fury and has disrupted billions in projected oil revenue, taken actions that have led to the freezing of nearly half a billion dollars in regime-linked cryptocurrency, and cracked down on Tehran’s shadow banking networks.
Treasury remains ready to take economic action against Iran’s defense industrial base so that Iran cannot reconstitute its production capacity and project power outside its borders. Treasury is also prepared to take action against any foreign company supporting illicit Iranian commerce, including airlines, and, as necessary, may impose secondary sanctions on foreign financial institutions that facilitate Iran’s activities—including those connected to the People’s Republic of China’s independent “teapot” oil refineries.
Any person or vessel facilitating the illicit trade of oil or other commodities, through covert trade or financial channels, risks exposure to U.S. sanctions. Treasury will vigorously target both traditional sanctions evasion schemes and the exploitation of digital assets while continuing to freeze funds stolen from the Iranian people.
Through the blockade, the Trump Administration is directly targeting the regime’s primary revenue stream, and any person or vessel facilitating the illicit flow of oil or other products risks exposure to U.S. sanctions.
FinCEN’s Advisory Program
The Financial Crimes Enforcement Network’s Advisory Program communicates priority money laundering, terrorist financing, and other illicit finance threats and vulnerabilities to the U.S. financial system. Financial institutions may use this information to support effective, risk-based, and reasonably designed AML/CFT programs and suspicious activity monitoring systems to help generate highly useful information for law enforcement and national security agencies. FinCEN’s Advisory Program has resulted in highly useful Suspicious Activity Reports that have helped law enforcement and national security agencies “follow the money” to uncover and disrupt criminal activity, protect the U.S. financial system, and hold illicit actors accountable.
FinCEN’s Whistleblower Program
FinCEN maintains a whistleblower program to encourage reporting on violations of the Bank Secrecy Act and certain sanctions and national security laws. Individuals who provide actionable information may be eligible for awards if their tip leads to a successful enforcement action. FinCEN encourages individuals with relevant information to submit whistleblower tips and learn more about FinCEN’s Whistleblower Program at www.fincen.gov/whistleblower-program.
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