_________________________________________________________
US State Dept Narcotics Report 2012 (introduction):
The Islamic Republic of Iran is a major transit route for opiates smuggled
from Afghanistan and Pakistan to the Persian Gulf, Turkey, Russia, and
Europe. A large share of opiates leaving Afghanistan transit Iran for
consumers in Central Asia, and Europe; a much smaller share ends up
in Russia. Knowledgeable observers estimate that at least 40 percent of
Afghan opium production enters Iran, with a large share of that 40
percent remaining for Iran’s own consumption.
In most years, Iran, according to Iranian statistics, seizes more illicit
opium-based drugs than any other country in the world. Iran’s reported
seizures of opium –the most abused drug in Iran – amounted to eight-
times more than all other countries’ opium seizures combined in 2010.
Since 2007, Iran has seized roughly one-third of all heroin seized in the
world, and more recently Iran’s heroin seizures make up almost half of
the heroin seized in the world. Iran’s opium and morphine seizures were
down in the first eight months of 2011, while seizures of heroin were at
nearly the same level as in 2010. Hashish seizures fell sharply (-26 %) in
the first eight months of 2011 from the same period in 2010.
Iranian traffickers continued to play a major role in trafficking
amphetamine-type stimulants (ATS) to countries in Southeast Asia.
These amphetamines are likely manufactured in Iran, as numerous labs
and large amounts of ATS have been seized inside Iran, and significant
seizures are made in Turkey, in addition to other countries bordering
Iran. Seizure statistics for amphetamines in Iran demonstrate the
emergence of a new drug threat. In 2011, reported seizures of
amphetamine in Iran increased ten-times from figures reported in 2008.
Treatment professionals in Iran are expressing concern that widespread
amphetamine abuse may overwhelm already limited treatment resources.
Iran has one of the most serious opiate addiction problems in the world.
Recent statistics on opiate abuse place Iran second in the world by
share of population using opiates, exceeded only by Afghanistan. Not all
opium users in Iran are addicts. Many Iranians smoke opium casually in
social circumstances or use it as a medicine, in small quantities.
However, highly addictive high-potency heroin is increasingly taken
intravenously, especially by young people. The amount of high-potency
heroin seized in Iran is on the rise.
Drug use has driven the spread of HIV/AIDS in the country. By mid 2011,
there were 23,125 people registered with HIV/AIDS infections. Injecting
drug use was a factor in contracting the disease in nearly 70 percent of
these cases. The average HIV prevalence among injecting drug users in
Iran is 14.3 percent. The total number of infected persons may be up to
80,000, according to the Iranian Ministry of Health.
Recently, Iran’s drug officials demonstrated a sharp reversal of their
former policies to incarcerate drug abusers; they now claim to
emphasize treatment over punishment. In addition to treatment clinics,
free needle programs and the distribution of condoms have been used
to curb HIV and other blood-borne disease infection rates in Iran.
Methadone and Buprenorpine are used to maintain addicts during
withdrawal treatment. Despite this new approach to dealing with addicts,
the penalties for drug related crimes in Iran remain high. International
human rights organizations condemn numerous executions for drug-
related crimes in Iran.
Iran is a party to the 1988 UN Drug Convention, but its laws do not bring
it into full compliance with the Convention. The UNODC is working with
Iran to modify laws, train the judiciary, and improve Iran’s court system.
For Full report, click here
_________________________________________________________
US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 3)
Iran is a source, transit, and destination country for men, women, and
children subjected to sex trafficking and forced labor. Iranian women are
trafficked internally for forced prostitution and forced marriage. Iranian
and Afghan children living in Iran are trafficked within the country for
commercial sexual exploitation – sometimes through forced marriages, in
which their new “husbands” force them into prostitution and involuntary
servitude as beggars or laborers to pay debts, provide income, or
support drug addiction of their families. There are reports of women and
girls being sold for marriage to men in Pakistan for the purpose of sexual
servitude. Young men and Afghan boys are forced into prostitution in
male brothels in southern Iran or to Afghan and Pakistani warlords.
Iranian women and children – both girls and boys – are also subjected to
sex trafficking in Pakistan, Turkey, Qatar, Kuwait, the United Arab
Emirates, Bahrain, Iraq, France, Germany, and the United Kingdom.
Some NGOs report that religious leaders and immigration officials are
involved in the sale of young girls and boys between nine and 14 years
old to men in Gulf states, particularly Bahrain, for commercial sexual
exploitation. According to these sources, a young girl or boy could be
sold for $15 to $20 or, in Iran, for as little as $5. The main purchasers of
child prostitution in Iran include truck drivers, religious seminaries, and
Afghan immigrant workers. Afghan women, boys and girls are also
trafficked through Iran to the Persian Gulf for commercial sexual
exploitation.
Men and women from Pakistan, Bangladesh, and Iraq migrate voluntarily
or are smuggled to Iran, or through Iran, to other Gulf states, Greece,
and Turkey seeking employment. Some subsequently are subjected to
conditions of forced labor or debt bondage, including through the use of
such practices as restriction of movement, nonpayment of wages, and
physical or sexual abuse. In Iran, reports indicate victims primarily work
in the construction and agricultural sectors, although this type of forced
labor may have declined over the past year due to the economic crisis.
There are reports that women from Azerbaijan and Tajikistan travel to
Iran to find employment and subsequently fall victim to forced
prostitution. Tajik women transit Iran and are forced into prostitution in
the UAE. NGO reports indicate criminal organizations, sometimes
politically connected, play a significant role in human trafficking to and
from Iran, particularly across the borders with Afghanistan and Pakistan
in connection with smuggling of migrants, drugs, and arms. There are
nearly one million Afghans living in Iran, some as refugees and others as
economic migrants, who are vulnerable to conditions of human trafficking.
The Government of Iran does not fully comply with the minimum
standards for the elimination of trafficking, and is not making significant
efforts to do so. Lack of access to Iran by U.S. government officials
impedes the collection of information on the country’s human trafficking
problem and the government’s efforts to curb it. The government did not
share information on its anti-trafficking efforts with the international
community during the reporting period. Publicly available information
from NGOs, the press, international organizations, and other
governments nonetheless indicate that the government is not taking
sufficient steps to address its extensive trafficking challenges. The
government did not report any law enforcement efforts to punish
trafficking offenders and continues to lack any semblance of victim
protection measures. Victims of trafficking are, by government policy,
detained and deported if foreign, or simply jailed or turned away if
Iranian, further compounding their trauma. The Government of Iran has
made no discernible efforts to address widespread government
corruption that facilitates trafficking in Iran. For these reasons, Iran is
placed on Tier 3 for a sixth consecutive year.
For full report click here
_________________________________________________________
US State Dept Terrorism Report 2009
Iran remained the most active state sponsor of terrorism. Iran’s financial,
material, and logistic support for terrorist and militant groups throughout
the Middle East and Central Asia had a direct impact on international
efforts to promote peace, threatened economic stability in the Gulf and
undermined the growth of democracy.
Iran remained the principal supporter of groups that are implacably
opposed to the Middle East Peace Process. The Qods Force, the
external operations branch of the Islamic Revolutionary Guard Corps
(IRGC), is the regime’s primary mechanism for cultivating and supporting
terrorists abroad. Iran provided weapons, training, and funding to
HAMAS and other Palestinian terrorist groups, including Palestine
Islamic Jihad (PIJ) and the Popular Front for the Liberation of Palestine-
General Command (PFLP-GC). Iran has provided hundreds of millions of
dollars in support to Lebanese Hizballah and has trained thousands of
Hizballah fighters at camps in Iran. Since the end of the 2006 Israeli-
Hizballah conflict, Iran has assisted Hizballah in rearming, in violation of
UN Security Council Resolution 1701.
Iran’s Qods Force provided training to the Taliban in Afghanistan on
small unit tactics, small arms, explosives, and indirect fire weapons.
Since at least 2006, Iran has arranged arms shipments to select Taliban
members, including small arms and associated ammunition, rocket
propelled grenades, mortar rounds, 107mm rockets, and plastic
explosives.
Despite its pledge to support the stabilization of Iraq, Iranian authorities
continued to provide lethal support, including weapons, training, funding,
and guidance, to Iraqi Shia militant groups that targeted U.S. and Iraqi
forces. The Qods Force continued to supply Iraqi militants with Iranian-
produced advanced rockets, sniper rifles, automatic weapons, and
mortars that have killed Iraqi and Coalition Forces, as well as civilians.
Iran was responsible for the increased lethality of some attacks on U.S.
forces by providing militants with the capability to assemble explosively
formed penetrators that were designed to defeat armored vehicles. The
Qods Force, in concert with Lebanese Hizballah, provided training
outside of Iraq and advisors inside Iraq for Shia militants in the
construction and use of sophisticated improvised explosive device
technology and other advanced weaponry.
Iran remained unwilling to bring to justice senior al-Qa’ida (AQ) members
it continued to detain, and refused to publicly identify those senior
members in its custody. Iran has repeatedly resisted numerous calls to
transfer custody of its AQ detainees to their countries of origin or third
countries for trial; it is reportedly holding Usama bin Ladin’s family
members under house arrest.
Senior IRGC, IRGC Qods Force, and Iranian government officials were
indicted by the Government of Argentina for their alleged roles in the
1994 terrorist bombing of the Argentine-Jewish Mutual Association
(AMIA); according to the Argentine State Prosecutor’s report, the attack
was initially proposed by the Qods Force. In 2007, INTERPOL issued a
“red notice” for six individuals wanted in connection to the bombing. One
of the individuals, Ahmad Vahidi, was named as Iran’s Defense Minister
in August 2009.
_________________________________________________________
AML News / Updates
April 23, 2012 - Executive order blocking the property and suspending
entry into the United States of certain persons with respect to grave
human rights abuses by the governments of Iran and Syria via
information technology
Read Executive Order
March 26, 2012 - EU Council Regulation (EU) No 267/2012
of 23 March 2012 concerning restrictive measures against Iran and
repealing Regulation (EU) No 961/2010
Read More
March 20, 2012 - OFAC release Iranian Transactions Regulations
Amendment
Read More
March 20, 2012 - OFAC release Publication of Statement of Licensing
Policy on Internet Freedom In Iran
Read More
March 18, 2012 - SWIFT instructed to disconnect sanctioned Iranian
banks following EU Council decision
Read More
March 18, 2012 - EU Council elaborates EU sanctions against Iran
Read More
February 27, 2012 - OFAC amends the Iranian Financial Sanctions
Regulations, 31 C.F.R. part 561 (the "IFSR"), and republishes them in
their entirety, to implement subsection 1245(d) of the National Defense
Authorization Act for Fiscal Year 2012 ("NDAA")
Read More
February 24, 2012 - OFAC is amending General License No. 5a and
reissuing the general license under the Weapons of Mass Destruction
Proliferators Sanctions Regulations, 31 C.F.R. Part 544; the Iranian
Transactions Regulations, 31 C.F.R. Part 560; and Executive Order
13599, in order to authorize certain transactions related to the arrest,
detention, and judicial sale of the MV Dianthe (f.k.a. Horsham, f.k.a. Iran
Bam, IMO No. 9323833), which is a vessel on OFAC’s Specially
Designated Nationals and Blocked Persons list.
Read General Licence
February 5, 2012 - Banks in UAE and Qatar stop financing trade with
Iran
Read More (Reuters)
January 25, 2012 - EU Council Implement Regulation (EU) No 54/2012
Read Regulation
January 15, 2012 - OFAC has updated its notice regarding the
implementation of certain sanctions under the Iran Sanctions Act of 1996
Read Notice
December 2, 2011 - EU Council Implement Regulation (EU) No
1245/2011 Iran (nuclear proliferation)
Read regulation
November 24, 2011 - All UK credit and financial institutions are
required to cease business relationships and transactions with all Iranian
banks, including their branches and subsidiaries, and the Central Bank
of Iran.
Read Treasury Order
November 22, 2011 - US Dept of the Treasury Finding that the Islamic
Republic of Iran is a Jurisdiction of Primary Money Laundering Concern
(as submitted to the Federal Register)
Read Notice of Findings
November 22, 2011 - US Dept of the Treasury Imposition of Special
Measure against the Islamic Republic of Iran as a Jurisdiction of Primary
Money Laundering Concern (as submitted to the Federal Register)
Read Notice of Proposed Rulemaking
October 7, 2011 - The U.S. Department of the Treasury's Financial
Crimes Enforcement Network (FinCEN) delivered to the Federal Register
a final rule to implement section 104(e) of the Comprehensive Iran
Sanctions, Accountability, and Divestment Act of 2010 (CISADA) to
complement Treasury's ongoing efforts to protect the international
financial system from abuse by Iran.
Read final rule
June 22, 2010 - FinCEN Issues Advisory to Provide Update on the
Continuing Illicit Finance Threat Emanating From Iran
Read More.....
June 9, 2010 - UN imposes additional sanctions on Iran.
Read More......
Links:
Worldwide AML Legislation (International Bar Association)
US State Dept Narcotics Report 2012 (introduction):
The Islamic Republic of Iran is a major transit route for opiates smuggled
from Afghanistan and Pakistan to the Persian Gulf, Turkey, Russia, and
Europe. A large share of opiates leaving Afghanistan transit Iran for
consumers in Central Asia, and Europe; a much smaller share ends up
in Russia. Knowledgeable observers estimate that at least 40 percent of
Afghan opium production enters Iran, with a large share of that 40
percent remaining for Iran’s own consumption.
In most years, Iran, according to Iranian statistics, seizes more illicit
opium-based drugs than any other country in the world. Iran’s reported
seizures of opium –the most abused drug in Iran – amounted to eight-
times more than all other countries’ opium seizures combined in 2010.
Since 2007, Iran has seized roughly one-third of all heroin seized in the
world, and more recently Iran’s heroin seizures make up almost half of
the heroin seized in the world. Iran’s opium and morphine seizures were
down in the first eight months of 2011, while seizures of heroin were at
nearly the same level as in 2010. Hashish seizures fell sharply (-26 %) in
the first eight months of 2011 from the same period in 2010.
Iranian traffickers continued to play a major role in trafficking
amphetamine-type stimulants (ATS) to countries in Southeast Asia.
These amphetamines are likely manufactured in Iran, as numerous labs
and large amounts of ATS have been seized inside Iran, and significant
seizures are made in Turkey, in addition to other countries bordering
Iran. Seizure statistics for amphetamines in Iran demonstrate the
emergence of a new drug threat. In 2011, reported seizures of
amphetamine in Iran increased ten-times from figures reported in 2008.
Treatment professionals in Iran are expressing concern that widespread
amphetamine abuse may overwhelm already limited treatment resources.
Iran has one of the most serious opiate addiction problems in the world.
Recent statistics on opiate abuse place Iran second in the world by
share of population using opiates, exceeded only by Afghanistan. Not all
opium users in Iran are addicts. Many Iranians smoke opium casually in
social circumstances or use it as a medicine, in small quantities.
However, highly addictive high-potency heroin is increasingly taken
intravenously, especially by young people. The amount of high-potency
heroin seized in Iran is on the rise.
Drug use has driven the spread of HIV/AIDS in the country. By mid 2011,
there were 23,125 people registered with HIV/AIDS infections. Injecting
drug use was a factor in contracting the disease in nearly 70 percent of
these cases. The average HIV prevalence among injecting drug users in
Iran is 14.3 percent. The total number of infected persons may be up to
80,000, according to the Iranian Ministry of Health.
Recently, Iran’s drug officials demonstrated a sharp reversal of their
former policies to incarcerate drug abusers; they now claim to
emphasize treatment over punishment. In addition to treatment clinics,
free needle programs and the distribution of condoms have been used
to curb HIV and other blood-borne disease infection rates in Iran.
Methadone and Buprenorpine are used to maintain addicts during
withdrawal treatment. Despite this new approach to dealing with addicts,
the penalties for drug related crimes in Iran remain high. International
human rights organizations condemn numerous executions for drug-
related crimes in Iran.
Iran is a party to the 1988 UN Drug Convention, but its laws do not bring
it into full compliance with the Convention. The UNODC is working with
Iran to modify laws, train the judiciary, and improve Iran’s court system.
For Full report, click here
_________________________________________________________
US State Dept Trafficking in Persons Report 2011 (introduction):
(Tier 3)
Iran is a source, transit, and destination country for men, women, and
children subjected to sex trafficking and forced labor. Iranian women are
trafficked internally for forced prostitution and forced marriage. Iranian
and Afghan children living in Iran are trafficked within the country for
commercial sexual exploitation – sometimes through forced marriages, in
which their new “husbands” force them into prostitution and involuntary
servitude as beggars or laborers to pay debts, provide income, or
support drug addiction of their families. There are reports of women and
girls being sold for marriage to men in Pakistan for the purpose of sexual
servitude. Young men and Afghan boys are forced into prostitution in
male brothels in southern Iran or to Afghan and Pakistani warlords.
Iranian women and children – both girls and boys – are also subjected to
sex trafficking in Pakistan, Turkey, Qatar, Kuwait, the United Arab
Emirates, Bahrain, Iraq, France, Germany, and the United Kingdom.
Some NGOs report that religious leaders and immigration officials are
involved in the sale of young girls and boys between nine and 14 years
old to men in Gulf states, particularly Bahrain, for commercial sexual
exploitation. According to these sources, a young girl or boy could be
sold for $15 to $20 or, in Iran, for as little as $5. The main purchasers of
child prostitution in Iran include truck drivers, religious seminaries, and
Afghan immigrant workers. Afghan women, boys and girls are also
trafficked through Iran to the Persian Gulf for commercial sexual
exploitation.
Men and women from Pakistan, Bangladesh, and Iraq migrate voluntarily
or are smuggled to Iran, or through Iran, to other Gulf states, Greece,
and Turkey seeking employment. Some subsequently are subjected to
conditions of forced labor or debt bondage, including through the use of
such practices as restriction of movement, nonpayment of wages, and
physical or sexual abuse. In Iran, reports indicate victims primarily work
in the construction and agricultural sectors, although this type of forced
labor may have declined over the past year due to the economic crisis.
There are reports that women from Azerbaijan and Tajikistan travel to
Iran to find employment and subsequently fall victim to forced
prostitution. Tajik women transit Iran and are forced into prostitution in
the UAE. NGO reports indicate criminal organizations, sometimes
politically connected, play a significant role in human trafficking to and
from Iran, particularly across the borders with Afghanistan and Pakistan
in connection with smuggling of migrants, drugs, and arms. There are
nearly one million Afghans living in Iran, some as refugees and others as
economic migrants, who are vulnerable to conditions of human trafficking.
The Government of Iran does not fully comply with the minimum
standards for the elimination of trafficking, and is not making significant
efforts to do so. Lack of access to Iran by U.S. government officials
impedes the collection of information on the country’s human trafficking
problem and the government’s efforts to curb it. The government did not
share information on its anti-trafficking efforts with the international
community during the reporting period. Publicly available information
from NGOs, the press, international organizations, and other
governments nonetheless indicate that the government is not taking
sufficient steps to address its extensive trafficking challenges. The
government did not report any law enforcement efforts to punish
trafficking offenders and continues to lack any semblance of victim
protection measures. Victims of trafficking are, by government policy,
detained and deported if foreign, or simply jailed or turned away if
Iranian, further compounding their trauma. The Government of Iran has
made no discernible efforts to address widespread government
corruption that facilitates trafficking in Iran. For these reasons, Iran is
placed on Tier 3 for a sixth consecutive year.
For full report click here
_________________________________________________________
US State Dept Terrorism Report 2009
Iran remained the most active state sponsor of terrorism. Iran’s financial,
material, and logistic support for terrorist and militant groups throughout
the Middle East and Central Asia had a direct impact on international
efforts to promote peace, threatened economic stability in the Gulf and
undermined the growth of democracy.
Iran remained the principal supporter of groups that are implacably
opposed to the Middle East Peace Process. The Qods Force, the
external operations branch of the Islamic Revolutionary Guard Corps
(IRGC), is the regime’s primary mechanism for cultivating and supporting
terrorists abroad. Iran provided weapons, training, and funding to
HAMAS and other Palestinian terrorist groups, including Palestine
Islamic Jihad (PIJ) and the Popular Front for the Liberation of Palestine-
General Command (PFLP-GC). Iran has provided hundreds of millions of
dollars in support to Lebanese Hizballah and has trained thousands of
Hizballah fighters at camps in Iran. Since the end of the 2006 Israeli-
Hizballah conflict, Iran has assisted Hizballah in rearming, in violation of
UN Security Council Resolution 1701.
Iran’s Qods Force provided training to the Taliban in Afghanistan on
small unit tactics, small arms, explosives, and indirect fire weapons.
Since at least 2006, Iran has arranged arms shipments to select Taliban
members, including small arms and associated ammunition, rocket
propelled grenades, mortar rounds, 107mm rockets, and plastic
explosives.
Despite its pledge to support the stabilization of Iraq, Iranian authorities
continued to provide lethal support, including weapons, training, funding,
and guidance, to Iraqi Shia militant groups that targeted U.S. and Iraqi
forces. The Qods Force continued to supply Iraqi militants with Iranian-
produced advanced rockets, sniper rifles, automatic weapons, and
mortars that have killed Iraqi and Coalition Forces, as well as civilians.
Iran was responsible for the increased lethality of some attacks on U.S.
forces by providing militants with the capability to assemble explosively
formed penetrators that were designed to defeat armored vehicles. The
Qods Force, in concert with Lebanese Hizballah, provided training
outside of Iraq and advisors inside Iraq for Shia militants in the
construction and use of sophisticated improvised explosive device
technology and other advanced weaponry.
Iran remained unwilling to bring to justice senior al-Qa’ida (AQ) members
it continued to detain, and refused to publicly identify those senior
members in its custody. Iran has repeatedly resisted numerous calls to
transfer custody of its AQ detainees to their countries of origin or third
countries for trial; it is reportedly holding Usama bin Ladin’s family
members under house arrest.
Senior IRGC, IRGC Qods Force, and Iranian government officials were
indicted by the Government of Argentina for their alleged roles in the
1994 terrorist bombing of the Argentine-Jewish Mutual Association
(AMIA); according to the Argentine State Prosecutor’s report, the attack
was initially proposed by the Qods Force. In 2007, INTERPOL issued a
“red notice” for six individuals wanted in connection to the bombing. One
of the individuals, Ahmad Vahidi, was named as Iran’s Defense Minister
in August 2009.
_________________________________________________________
AML News / Updates
April 23, 2012 - Executive order blocking the property and suspending
entry into the United States of certain persons with respect to grave
human rights abuses by the governments of Iran and Syria via
information technology
Read Executive Order
March 26, 2012 - EU Council Regulation (EU) No 267/2012
of 23 March 2012 concerning restrictive measures against Iran and
repealing Regulation (EU) No 961/2010
Read More
March 20, 2012 - OFAC release Iranian Transactions Regulations
Amendment
Read More
March 20, 2012 - OFAC release Publication of Statement of Licensing
Policy on Internet Freedom In Iran
Read More
March 18, 2012 - SWIFT instructed to disconnect sanctioned Iranian
banks following EU Council decision
Read More
March 18, 2012 - EU Council elaborates EU sanctions against Iran
Read More
February 27, 2012 - OFAC amends the Iranian Financial Sanctions
Regulations, 31 C.F.R. part 561 (the "IFSR"), and republishes them in
their entirety, to implement subsection 1245(d) of the National Defense
Authorization Act for Fiscal Year 2012 ("NDAA")
Read More
February 24, 2012 - OFAC is amending General License No. 5a and
reissuing the general license under the Weapons of Mass Destruction
Proliferators Sanctions Regulations, 31 C.F.R. Part 544; the Iranian
Transactions Regulations, 31 C.F.R. Part 560; and Executive Order
13599, in order to authorize certain transactions related to the arrest,
detention, and judicial sale of the MV Dianthe (f.k.a. Horsham, f.k.a. Iran
Bam, IMO No. 9323833), which is a vessel on OFAC’s Specially
Designated Nationals and Blocked Persons list.
Read General Licence
February 5, 2012 - Banks in UAE and Qatar stop financing trade with
Iran
Read More (Reuters)
January 25, 2012 - EU Council Implement Regulation (EU) No 54/2012
Read Regulation
January 15, 2012 - OFAC has updated its notice regarding the
implementation of certain sanctions under the Iran Sanctions Act of 1996
Read Notice
December 2, 2011 - EU Council Implement Regulation (EU) No
1245/2011 Iran (nuclear proliferation)
Read regulation
November 24, 2011 - All UK credit and financial institutions are
required to cease business relationships and transactions with all Iranian
banks, including their branches and subsidiaries, and the Central Bank
of Iran.
Read Treasury Order
November 22, 2011 - US Dept of the Treasury Finding that the Islamic
Republic of Iran is a Jurisdiction of Primary Money Laundering Concern
(as submitted to the Federal Register)
Read Notice of Findings
November 22, 2011 - US Dept of the Treasury Imposition of Special
Measure against the Islamic Republic of Iran as a Jurisdiction of Primary
Money Laundering Concern (as submitted to the Federal Register)
Read Notice of Proposed Rulemaking
October 7, 2011 - The U.S. Department of the Treasury's Financial
Crimes Enforcement Network (FinCEN) delivered to the Federal Register
a final rule to implement section 104(e) of the Comprehensive Iran
Sanctions, Accountability, and Divestment Act of 2010 (CISADA) to
complement Treasury's ongoing efforts to protect the international
financial system from abuse by Iran.
Read final rule
June 22, 2010 - FinCEN Issues Advisory to Provide Update on the
Continuing Illicit Finance Threat Emanating From Iran
Read More.....
June 9, 2010 - UN imposes additional sanctions on Iran.
Read More......
Links:
Worldwide AML Legislation (International Bar Association)
|
|
FATF Statement re AML Strategic Deficiencies:
Date: 16 February 2012
The FATF remains particularly and exceptionally concerned about
Iran’s failure to address the risk of terrorist financing and the
serious threat this poses to the integrity of the international
financial system, despite Iran’s previous engagement with the
FATF.
The FATF reaffirms its call on members and urges all jurisdictions
to advise their financial institutions to give special attention to
business relationships and transactions with Iran, including Iranian
companies and financial institutions. In addition to enhanced
scrutiny, the FATF reaffirms its 25 February 2009 call on its
members and urges all jurisdictions to apply effective counter-
measures to protect their financial sectors from money laundering
and financing of terrorism (ML/FT) risks emanating from Iran.
FATF continues to urge jurisdictions to protect against
correspondent relationships being used to bypass or evade
counter-measures and risk mitigation practices and to take into
account ML/FT risks when considering requests by Iranian
financial institutions to open branches and subsidiaries in their
jurisdiction. Due to the continuing terrorist financing threat
emanating from Iran, jurisdictions should consider the steps
already taken and possible additional safeguards or strengthen
existing ones.
The FATF urges Iran to immediately and meaningfully address its
AML/CFT deficiencies, in particular by criminalising terrorist
financing and effectively implementing suspicious transaction
reporting (STR) requirements. If Iran fails to take concrete steps
to improve its CFT regime, the FATF will consider calling on its
members and urging all jurisdictions to strengthen counter-
measures in June 2012.
____________________________________________________
Sanctions:
May 2, 2012 - US President signs an Executive Order (E.O.),
“Prohibiting Certain Transactions with and Suspending Entry into
the United States of Foreign Sanctions Evaders with Respect to
Iran and Syria,” providing the U.S. Treasury Department with a
new authority to tighten further the U.S. sanctions on Iran and
Syria.
Read Executive Order
April 25, 2012 - UK Treasury issue Supplement to Notice on Iran
(nuclear proliferation) of 26 March 2012. Restrictions on the
provision of insurance and reinsurance relating to the import,
purchase or transport of Iranian crude oil, petroleum products and
petrochemical products.
Read Supplement
April 23, 2012 - Executive order blocking the property and
suspending entry into the United States of certain persons with
respect to grave human rights abuses by the governments of Iran
and Syria via information technology
Read Executive Order
March 26, 2012 - EU Council Regulation (EU) No 267/2012
of 23 March 2012 concerning restrictive measures against Iran
and repealing Regulation (EU) No 961/2010
Read More
March 20, 2012 - OFAC release Iranian Transactions
Regulations Amendment
Read More
March 20, 2012 - OFAC release Publication of Statement of
Licensing Policy on Internet Freedom In Iran
Read More
March 18, 2012 - SWIFT instructed to disconnect sanctioned
Iranian banks following EU Council decision
Read More
March 18, 2012 - EU Council elaborates EU sanctions against
Iran
Read More
February 24, 2012 - OFAC is amending General License No. 5a
and reissuing the general license under the Weapons of Mass
Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part
544; the Iranian Transactions Regulations, 31 C.F.R. Part 560;
and Executive Order 13599, in order to authorize certain
transactions related to the arrest, detention, and judicial sale of
the MV Dianthe (f.k.a. Horsham, f.k.a. Iran Bam, IMO No.
9323833), which is a vessel on OFAC’s Specially Designated
Nationals and Blocked Persons list.
Read General Licence
15 February, 2012 - US Treasury Issues Guidance Concerning
National Defense Authorization Act Sanctions on Iran
Read Guidance
7 February 2012 - The US President has signed a new Executive
Order blocking the property and interests in property of the
Government of Iran and Iranian financial institutions. The E.O.
requires U.S. persons to block all property and interests in
property of the Government of Iran (including the Central Bank of
Iran), of all Iranian financial institutions, and of all persons
determined by the Secretary of the Treasury to be owned by,
controlled by, or acting for or on behalf of any of those parties,
when that property comes within the United States or within the
possession or control of U.S. persons.
Read more
January 25, 2012 - EU Council Implement Regulation (EU) No
54/2012 The Decision contains a range of measures, including:
an asset freeze of further entities and individuals, including the
Central Bank of Iran and Bank Tejarat;
a ban on the purchase, import or transport from Iran of crude oil
and petroleum products; and
a ban on the sale, purchase, transportation or brokering of gold,
precious metals and diamonds to, from or for the Government of
Iran.
Read Regulation
January 15, 2012 - OFAC has updated its notice regarding the
implementation of certain sanctions under the Iran Sanctions Act
of 1996
Read Notice
December 2, 2011 - EU Council Implement Regulation (EU) No
1245/2011 Iran (nuclear proliferation)
Read regulation
November 24, 2011 - All UK credit and financial institutions are
required to cease business relationships and transactions with all
Iranian banks, including their branches and subsidiaries, and the
Central Bank of Iran.
Read Treasury Order
There are extensive trade and financial sanctions in place against
Iran as a result of United Nations, EU and US sanctions and
embargoes. These include:
* prohibitions on the sale, supply, transfer or export of dual-use
goods and technology
* prohibitions on the sale, supply, transfer or export of key
equipment and technology for the oil and gas industry (with a
limited exemption for transactions required by, or obligations
arising from, contracts that were in place before 27 October 2010)
* an arms embargo and a prohibition on the supply of equipment
that could be used for human rights abuses
* prohibition on the purchase, import or transport from Iran of dual-
use and certain other goods and technology
* prohibitions on the provision of brokering services and technical
and financial assistance related to any goods and technology
whose supply is prohibited; prohibitions on investment in Iranian
entities engaged in manufacturing those items
* prohibitions on investment in Iranian entities or bodies engaged
in the exploration or production of crude oil and natural gas, the
refining of fuels or the liquefaction of natural gas
* asset freezes against listed individuals and entities and a
prohibition of making economic resources available to them
(including by the supply of goods and services which may be used
to obtain funds)
* restrictions on transfers of funds to and from Iran, and
restrictions on Iran's access to the insurance and bond markets
* restrictions on providing certain services on Iranian ships and
cargo aircraft
By the adoption of UNSCR 1737 (2006) on 23 December 2006,
the United Nations, amongst other matters, introduced financial
sanctions against those persons designated in the Annex to
Resolution 1737 (2006), by the competent United Nations
Sanctions Committee or by the UN Security Council as persons
who engage in, directly associate with or provide support for Iran's
proliferation sensitive nuclear activities or the development of
nuclear weapon delivery systems, or persons or entities acting on
their behalf or at their direction, or entities owned or controlled by
them, including through illicit means.
All states were called on to exercise vigilance over the activities of
financial institutions in their territories with all banks domiciled in
Iran and their branches and subsidiaries abroad. The resolution
followed statements issued by the Financial Action Task Force
(FATF) on 28 February 2008 and 11 October 2007 calling on
FATF member states to advise their financial institutions to take
the risk arising from deficiencies in Iran's anti-money-laundering
and counter-terrorist financing regime into account for enhanced
due diligence.
For further information, please visit the following link: -
http://www.un.org/sc/committees/
On June 9, 2010 the UN Security Council imposed additional
sanctions on Iran. For further information, please visit the
following link: -
www.un.org/News/Press/docs/2010/sc9948.doc.htm
For further information on EU restrictive measures currently in
force, please visit the following link: -
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
For further information on US sanctions, please visit the following
link: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/iran.aspx
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2012:
Although not considered a financial hub, Iran has a large
underground economy, spurred by restrictive taxation,
widespread smuggling, currency exchange controls, capital flight,
and a large Iranian expatriate community. Iran is a major transit
route for opiates smuggled from Afghanistan through Pakistan to
the Persian Gulf, Turkey, Russia, and Europe. At least 40% of
opiates leaving Afghanistan enters or transits Iran for domestic
consumption or for consumers in Russia and Europe. Illicit
proceeds from narcotics trafficking are used to purchase goods in
the domestic Iranian market; those goods are often exported and
sold in Dubai. Iran’s merchant community makes active use of
money and value transfer systems, including hawala and
moneylenders. Counter-valuation in hawala transactions is often
accomplished via trade, thus trade-based transactions are likely a
prevalent form of money laundering. Many hawaladars and
traditional bazaari are linked directly to the regional hawala hub in
Dubai. Over 300,000 Iranians reside in Dubai, with approximately
8,200 Iranian-owned companies based there. Iran’s real estate
market is also used to launder money. There also are reports that
billions of dollars in Iranian capital have been invested in the
United Arab Emirates, particularly in Dubai real estate.
On November 21, 2011, Iran was identified by the U.S.
Government as a state of primary money laundering concern
pursuant to section 311 of the USA PATRIOT Act. Widespread
corruption and economic sanctions, as well as evasion of those
sanctions, have undermined the potential for private sector
growth and facilitated money laundering. The Financial Action
Task Force (FATF) has repeatedly warned of Iran’s failure to
address the risks of terrorist financing. The FATF urges
jurisdictions around the world to impose countermeasures to
protect their financial sectors from illicit finance emanating from
Iran. In October 2011, the FATF urged all members and
jurisdictions to advise their financial institutions to give special
attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions.
In 1984, the Department of State designated Iran as a state
sponsor of terrorism. Iran continues to provide material support,
including resources and guidance, to multiple terrorist
organizations and other groups that undermine the stability of the
Middle East and Central Asia. Hamas, Hizballah, and the
Palestinian Islamic Jihad (PIJ) maintain representative offices in
Tehran in part to help coordinate Iranian financing and training.
Although Iran has established an international banking network,
with many large state-owned banks that have foreign branches
and subsidiaries in Europe, the Middle East, Asia, and the
Western Hemisphere, Iranian banks have a diminishing
international presence in these regions as a growing number of
governments move to sanction Iranian financial institutions in
response to UN, U.S., and autonomous sanctions regimes as well
as the FATF statements on Iran’s lack of adequate anti-money
laundering/counter-terrorist financing (AML/CFT) controls. Iran is
known to use its state-owned banks to channel funds to terrorist
organizations and finance its nuclear and ballistic missile
programs. The United States has designated at least 20 banks
and subsidiaries under counter-proliferation and terrorism
authorities.
Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of U.S. currency; currency derived from illegal sales in
the U.S.; or that otherwise significantly affect the U.S.: Not
available
Criminalization of Money Laundering:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: YES
Know-your-customer (KYC) rules:
Enhanced due diligence procedures for PEPs: Foreign: Not
available Domestic: Not available
KYC covered entities: Central Bank, banks, financial and credit
institutions, insurance companies (including the state regulator
and reinsurance provider), interest-free funds, charity
organizations and institutions, municipalities, notaries, lawyers,
accountants, auditors, authorized specialists of the Justice
Ministry, and official inspectors
Suspicious Transaction Reporting (STR) Requirements:
Number of STRs received and time frame: Not available
Number of CTRs received and time frame: Not available
STR covered entities: Central Bank, banks, financial and credit
institutions, insurance companies (including the state regulator
and reinsurance provider), interest-free funds, charity
organizations and institutions, municipalities, notaries, lawyers,
accountants, auditors, authorized specialists of the Justice
Ministry, and official inspectors
Money Laundering Criminal Prosecutions/Convictions:
Prosecutions: Not available
Convictions: None
Records exchange mechanism:
With U.S.: MLAT: NO Other: NO
With other governments/jurisdictions: Not available
Iran is not a member of any Financial Action Task Force (FATF)-
style regional body.
Enforcement and implementation issues and comments:
Since 2006, the U.S. has taken a number of targeted financial
actions against key Iranian financial institutions, entities, and
individuals under non-proliferation, counter-terrorism, human
rights, and Iraq-related authorities, i.e., Executive Order 13382,
Executive Order 13224, Executive Order 13553, and Executive
Order 13438, respectively. To date, the Departments of Treasury
and State have designated over 300 Iranian entities and
individuals for proliferation-related activity under Executive Order
13382. Additionally, the United Nations Security Council (UNSC)
has passed numerous resolutions that impose sanctions on Iran.
The most recent of these, UNSCR 1929, was adopted in June
2010.
UNSCR 1929 recognizes the potential connection between Iran’s
revenues derived from its energy sector and the funding of its
proliferation of sensitive nuclear activities. In 2010, in recognition
of that connection, the United States adopted the Comprehensive
Iran Sanctions, Accountability, and Divestment Act (CISADA),
which makes sanctionable certain activities in Iran’s energy
sector, including the provision of refined petroleum products to
Iran.
On December 31, 2011, the National Defense Authorization Act
for Fiscal Year 2012 was signed into law. Under Section 1245 of
the Act, foreign financial institutions that knowingly facilitate
significant financial transactions with the Central Bank of Iran or
with Iranian financial institutions designated by Treasury risk
being cut off from direct access to the U.S. financial system. This
legislation builds upon the sanctions from previous U.S. legislation
and UNSC resolutions.
The following are some examples of notable designations under
Executive Orders: 20 Iranian-linked banks (including Bank Refah
in 2011), located in Iran and overseas, have been designated in
connection with Iran’s proliferation activities; one state-owned
Iranian bank (Bank Saderat and its foreign operations) was
designated for funneling money to terrorist organizations; the
Qods Force, a branch of the Iranian Revolutionary Guard Corps
(IRGC), was designated for providing material support to the
Taliban, Lebanese Hizballah, and Palestinian Islamic Jihad; and,
the Martyrs Foundation (also known as Bonyad Shahid), an
Iranian parastatal organization that channels financial support
from Iran to several terrorist organizations in the Levant, including
Hizballah, Hamas, and the PIJ, has been designated along with
Lebanon- and U.S.-based affiliates.
In October 2007, the FATF issued its first public statement
expressing concern over Iran’s lack of a comprehensive AML/CFT
framework. In February 2009, the FATF urged all jurisdictions to
apply effective countermeasures to protect their financial sectors
from the money laundering/terrorist financing risks emanating
from Iran and also stated that jurisdictions should protect against
correspondent relationships being used to bypass or evade
countermeasures or risk mitigation practices. In October 2011, the
FATF reiterated its call for countermeasures. The FATF urges Iran
to immediately and meaningfully address its AML/CFT
deficiencies, in particular by criminalizing terrorist financing and
effectively implementing suspicious transaction reporting
requirements.
Since February 2007, the European Union (EU) has also adopted
numerous measures to implement the UNSCRs on Iran and
further protect the EU from Iranian threats. For example, in 2010,
the EU adopted significant new measures against Iran, including
new sanctions on several Iranian banks and the IRGC; enhanced
vigilance by way of additional reporting and prior authorization for
any funds transfers to and from an Iranian person, entity, or body
above a certain threshold amount; a prohibition on the
establishment of new Iranian bank branches, subsidiaries, joint
ventures, and correspondent accounts; and other restrictions on
insurance, bonds, energy, and trade.
Numerous countries around the world also have restricted their
financial and business dealings with Iran in response to both the
UNSC measures on Iran as well as the FATF statements on Iran’s
lack of adequate AML/CFT controls. A growing number of
governments have moved to designate Iranian banks, and many
of the world’s leading financial institutions have voluntarily chosen
to reduce or cut ties with Iranian banks.
Iran is ranked 120 out of 183 countries listed in Transparency
International’s 2011 Corruption Perception Index. There is
pervasive corruption within the ruling and religious elite,
government ministries, and government-controlled business
enterprises.
In 2010, the Government of Iran teamed with United Nations
Office on Drugs and Crime to establish a financial intelligence unit
(FIU). The Iranian FIU reportedly will focus on suspicious financial
transactions linked to illicit narcotics proceeds. No entity has been
able to assess whether Iran’s FIU meets international standards.
Date: 16 February 2012
The FATF remains particularly and exceptionally concerned about
Iran’s failure to address the risk of terrorist financing and the
serious threat this poses to the integrity of the international
financial system, despite Iran’s previous engagement with the
FATF.
The FATF reaffirms its call on members and urges all jurisdictions
to advise their financial institutions to give special attention to
business relationships and transactions with Iran, including Iranian
companies and financial institutions. In addition to enhanced
scrutiny, the FATF reaffirms its 25 February 2009 call on its
members and urges all jurisdictions to apply effective counter-
measures to protect their financial sectors from money laundering
and financing of terrorism (ML/FT) risks emanating from Iran.
FATF continues to urge jurisdictions to protect against
correspondent relationships being used to bypass or evade
counter-measures and risk mitigation practices and to take into
account ML/FT risks when considering requests by Iranian
financial institutions to open branches and subsidiaries in their
jurisdiction. Due to the continuing terrorist financing threat
emanating from Iran, jurisdictions should consider the steps
already taken and possible additional safeguards or strengthen
existing ones.
The FATF urges Iran to immediately and meaningfully address its
AML/CFT deficiencies, in particular by criminalising terrorist
financing and effectively implementing suspicious transaction
reporting (STR) requirements. If Iran fails to take concrete steps
to improve its CFT regime, the FATF will consider calling on its
members and urging all jurisdictions to strengthen counter-
measures in June 2012.
____________________________________________________
Sanctions:
May 2, 2012 - US President signs an Executive Order (E.O.),
“Prohibiting Certain Transactions with and Suspending Entry into
the United States of Foreign Sanctions Evaders with Respect to
Iran and Syria,” providing the U.S. Treasury Department with a
new authority to tighten further the U.S. sanctions on Iran and
Syria.
Read Executive Order
April 25, 2012 - UK Treasury issue Supplement to Notice on Iran
(nuclear proliferation) of 26 March 2012. Restrictions on the
provision of insurance and reinsurance relating to the import,
purchase or transport of Iranian crude oil, petroleum products and
petrochemical products.
Read Supplement
April 23, 2012 - Executive order blocking the property and
suspending entry into the United States of certain persons with
respect to grave human rights abuses by the governments of Iran
and Syria via information technology
Read Executive Order
March 26, 2012 - EU Council Regulation (EU) No 267/2012
of 23 March 2012 concerning restrictive measures against Iran
and repealing Regulation (EU) No 961/2010
Read More
March 20, 2012 - OFAC release Iranian Transactions
Regulations Amendment
Read More
March 20, 2012 - OFAC release Publication of Statement of
Licensing Policy on Internet Freedom In Iran
Read More
March 18, 2012 - SWIFT instructed to disconnect sanctioned
Iranian banks following EU Council decision
Read More
March 18, 2012 - EU Council elaborates EU sanctions against
Iran
Read More
February 24, 2012 - OFAC is amending General License No. 5a
and reissuing the general license under the Weapons of Mass
Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part
544; the Iranian Transactions Regulations, 31 C.F.R. Part 560;
and Executive Order 13599, in order to authorize certain
transactions related to the arrest, detention, and judicial sale of
the MV Dianthe (f.k.a. Horsham, f.k.a. Iran Bam, IMO No.
9323833), which is a vessel on OFAC’s Specially Designated
Nationals and Blocked Persons list.
Read General Licence
15 February, 2012 - US Treasury Issues Guidance Concerning
National Defense Authorization Act Sanctions on Iran
Read Guidance
7 February 2012 - The US President has signed a new Executive
Order blocking the property and interests in property of the
Government of Iran and Iranian financial institutions. The E.O.
requires U.S. persons to block all property and interests in
property of the Government of Iran (including the Central Bank of
Iran), of all Iranian financial institutions, and of all persons
determined by the Secretary of the Treasury to be owned by,
controlled by, or acting for or on behalf of any of those parties,
when that property comes within the United States or within the
possession or control of U.S. persons.
Read more
January 25, 2012 - EU Council Implement Regulation (EU) No
54/2012 The Decision contains a range of measures, including:
an asset freeze of further entities and individuals, including the
Central Bank of Iran and Bank Tejarat;
a ban on the purchase, import or transport from Iran of crude oil
and petroleum products; and
a ban on the sale, purchase, transportation or brokering of gold,
precious metals and diamonds to, from or for the Government of
Iran.
Read Regulation
January 15, 2012 - OFAC has updated its notice regarding the
implementation of certain sanctions under the Iran Sanctions Act
of 1996
Read Notice
December 2, 2011 - EU Council Implement Regulation (EU) No
1245/2011 Iran (nuclear proliferation)
Read regulation
November 24, 2011 - All UK credit and financial institutions are
required to cease business relationships and transactions with all
Iranian banks, including their branches and subsidiaries, and the
Central Bank of Iran.
Read Treasury Order
There are extensive trade and financial sanctions in place against
Iran as a result of United Nations, EU and US sanctions and
embargoes. These include:
* prohibitions on the sale, supply, transfer or export of dual-use
goods and technology
* prohibitions on the sale, supply, transfer or export of key
equipment and technology for the oil and gas industry (with a
limited exemption for transactions required by, or obligations
arising from, contracts that were in place before 27 October 2010)
* an arms embargo and a prohibition on the supply of equipment
that could be used for human rights abuses
* prohibition on the purchase, import or transport from Iran of dual-
use and certain other goods and technology
* prohibitions on the provision of brokering services and technical
and financial assistance related to any goods and technology
whose supply is prohibited; prohibitions on investment in Iranian
entities engaged in manufacturing those items
* prohibitions on investment in Iranian entities or bodies engaged
in the exploration or production of crude oil and natural gas, the
refining of fuels or the liquefaction of natural gas
* asset freezes against listed individuals and entities and a
prohibition of making economic resources available to them
(including by the supply of goods and services which may be used
to obtain funds)
* restrictions on transfers of funds to and from Iran, and
restrictions on Iran's access to the insurance and bond markets
* restrictions on providing certain services on Iranian ships and
cargo aircraft
By the adoption of UNSCR 1737 (2006) on 23 December 2006,
the United Nations, amongst other matters, introduced financial
sanctions against those persons designated in the Annex to
Resolution 1737 (2006), by the competent United Nations
Sanctions Committee or by the UN Security Council as persons
who engage in, directly associate with or provide support for Iran's
proliferation sensitive nuclear activities or the development of
nuclear weapon delivery systems, or persons or entities acting on
their behalf or at their direction, or entities owned or controlled by
them, including through illicit means.
All states were called on to exercise vigilance over the activities of
financial institutions in their territories with all banks domiciled in
Iran and their branches and subsidiaries abroad. The resolution
followed statements issued by the Financial Action Task Force
(FATF) on 28 February 2008 and 11 October 2007 calling on
FATF member states to advise their financial institutions to take
the risk arising from deficiencies in Iran's anti-money-laundering
and counter-terrorist financing regime into account for enhanced
due diligence.
For further information, please visit the following link: -
http://www.un.org/sc/committees/
On June 9, 2010 the UN Security Council imposed additional
sanctions on Iran. For further information, please visit the
following link: -
www.un.org/News/Press/docs/2010/sc9948.doc.htm
For further information on EU restrictive measures currently in
force, please visit the following link: -
http://ec.europa.
eu/external_relations/cfsp/sanctions/docs/measures_en.pdf
For further information on US sanctions, please visit the following
link: -
http://www.treasury.gov/resource-
center/sanctions/Programs/pages/iran.aspx
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2012:
Although not considered a financial hub, Iran has a large
underground economy, spurred by restrictive taxation,
widespread smuggling, currency exchange controls, capital flight,
and a large Iranian expatriate community. Iran is a major transit
route for opiates smuggled from Afghanistan through Pakistan to
the Persian Gulf, Turkey, Russia, and Europe. At least 40% of
opiates leaving Afghanistan enters or transits Iran for domestic
consumption or for consumers in Russia and Europe. Illicit
proceeds from narcotics trafficking are used to purchase goods in
the domestic Iranian market; those goods are often exported and
sold in Dubai. Iran’s merchant community makes active use of
money and value transfer systems, including hawala and
moneylenders. Counter-valuation in hawala transactions is often
accomplished via trade, thus trade-based transactions are likely a
prevalent form of money laundering. Many hawaladars and
traditional bazaari are linked directly to the regional hawala hub in
Dubai. Over 300,000 Iranians reside in Dubai, with approximately
8,200 Iranian-owned companies based there. Iran’s real estate
market is also used to launder money. There also are reports that
billions of dollars in Iranian capital have been invested in the
United Arab Emirates, particularly in Dubai real estate.
On November 21, 2011, Iran was identified by the U.S.
Government as a state of primary money laundering concern
pursuant to section 311 of the USA PATRIOT Act. Widespread
corruption and economic sanctions, as well as evasion of those
sanctions, have undermined the potential for private sector
growth and facilitated money laundering. The Financial Action
Task Force (FATF) has repeatedly warned of Iran’s failure to
address the risks of terrorist financing. The FATF urges
jurisdictions around the world to impose countermeasures to
protect their financial sectors from illicit finance emanating from
Iran. In October 2011, the FATF urged all members and
jurisdictions to advise their financial institutions to give special
attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions.
In 1984, the Department of State designated Iran as a state
sponsor of terrorism. Iran continues to provide material support,
including resources and guidance, to multiple terrorist
organizations and other groups that undermine the stability of the
Middle East and Central Asia. Hamas, Hizballah, and the
Palestinian Islamic Jihad (PIJ) maintain representative offices in
Tehran in part to help coordinate Iranian financing and training.
Although Iran has established an international banking network,
with many large state-owned banks that have foreign branches
and subsidiaries in Europe, the Middle East, Asia, and the
Western Hemisphere, Iranian banks have a diminishing
international presence in these regions as a growing number of
governments move to sanction Iranian financial institutions in
response to UN, U.S., and autonomous sanctions regimes as well
as the FATF statements on Iran’s lack of adequate anti-money
laundering/counter-terrorist financing (AML/CFT) controls. Iran is
known to use its state-owned banks to channel funds to terrorist
organizations and finance its nuclear and ballistic missile
programs. The United States has designated at least 20 banks
and subsidiaries under counter-proliferation and terrorism
authorities.
Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of U.S. currency; currency derived from illegal sales in
the U.S.; or that otherwise significantly affect the U.S.: Not
available
Criminalization of Money Laundering:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: YES
Know-your-customer (KYC) rules:
Enhanced due diligence procedures for PEPs: Foreign: Not
available Domestic: Not available
KYC covered entities: Central Bank, banks, financial and credit
institutions, insurance companies (including the state regulator
and reinsurance provider), interest-free funds, charity
organizations and institutions, municipalities, notaries, lawyers,
accountants, auditors, authorized specialists of the Justice
Ministry, and official inspectors
Suspicious Transaction Reporting (STR) Requirements:
Number of STRs received and time frame: Not available
Number of CTRs received and time frame: Not available
STR covered entities: Central Bank, banks, financial and credit
institutions, insurance companies (including the state regulator
and reinsurance provider), interest-free funds, charity
organizations and institutions, municipalities, notaries, lawyers,
accountants, auditors, authorized specialists of the Justice
Ministry, and official inspectors
Money Laundering Criminal Prosecutions/Convictions:
Prosecutions: Not available
Convictions: None
Records exchange mechanism:
With U.S.: MLAT: NO Other: NO
With other governments/jurisdictions: Not available
Iran is not a member of any Financial Action Task Force (FATF)-
style regional body.
Enforcement and implementation issues and comments:
Since 2006, the U.S. has taken a number of targeted financial
actions against key Iranian financial institutions, entities, and
individuals under non-proliferation, counter-terrorism, human
rights, and Iraq-related authorities, i.e., Executive Order 13382,
Executive Order 13224, Executive Order 13553, and Executive
Order 13438, respectively. To date, the Departments of Treasury
and State have designated over 300 Iranian entities and
individuals for proliferation-related activity under Executive Order
13382. Additionally, the United Nations Security Council (UNSC)
has passed numerous resolutions that impose sanctions on Iran.
The most recent of these, UNSCR 1929, was adopted in June
2010.
UNSCR 1929 recognizes the potential connection between Iran’s
revenues derived from its energy sector and the funding of its
proliferation of sensitive nuclear activities. In 2010, in recognition
of that connection, the United States adopted the Comprehensive
Iran Sanctions, Accountability, and Divestment Act (CISADA),
which makes sanctionable certain activities in Iran’s energy
sector, including the provision of refined petroleum products to
Iran.
On December 31, 2011, the National Defense Authorization Act
for Fiscal Year 2012 was signed into law. Under Section 1245 of
the Act, foreign financial institutions that knowingly facilitate
significant financial transactions with the Central Bank of Iran or
with Iranian financial institutions designated by Treasury risk
being cut off from direct access to the U.S. financial system. This
legislation builds upon the sanctions from previous U.S. legislation
and UNSC resolutions.
The following are some examples of notable designations under
Executive Orders: 20 Iranian-linked banks (including Bank Refah
in 2011), located in Iran and overseas, have been designated in
connection with Iran’s proliferation activities; one state-owned
Iranian bank (Bank Saderat and its foreign operations) was
designated for funneling money to terrorist organizations; the
Qods Force, a branch of the Iranian Revolutionary Guard Corps
(IRGC), was designated for providing material support to the
Taliban, Lebanese Hizballah, and Palestinian Islamic Jihad; and,
the Martyrs Foundation (also known as Bonyad Shahid), an
Iranian parastatal organization that channels financial support
from Iran to several terrorist organizations in the Levant, including
Hizballah, Hamas, and the PIJ, has been designated along with
Lebanon- and U.S.-based affiliates.
In October 2007, the FATF issued its first public statement
expressing concern over Iran’s lack of a comprehensive AML/CFT
framework. In February 2009, the FATF urged all jurisdictions to
apply effective countermeasures to protect their financial sectors
from the money laundering/terrorist financing risks emanating
from Iran and also stated that jurisdictions should protect against
correspondent relationships being used to bypass or evade
countermeasures or risk mitigation practices. In October 2011, the
FATF reiterated its call for countermeasures. The FATF urges Iran
to immediately and meaningfully address its AML/CFT
deficiencies, in particular by criminalizing terrorist financing and
effectively implementing suspicious transaction reporting
requirements.
Since February 2007, the European Union (EU) has also adopted
numerous measures to implement the UNSCRs on Iran and
further protect the EU from Iranian threats. For example, in 2010,
the EU adopted significant new measures against Iran, including
new sanctions on several Iranian banks and the IRGC; enhanced
vigilance by way of additional reporting and prior authorization for
any funds transfers to and from an Iranian person, entity, or body
above a certain threshold amount; a prohibition on the
establishment of new Iranian bank branches, subsidiaries, joint
ventures, and correspondent accounts; and other restrictions on
insurance, bonds, energy, and trade.
Numerous countries around the world also have restricted their
financial and business dealings with Iran in response to both the
UNSC measures on Iran as well as the FATF statements on Iran’s
lack of adequate AML/CFT controls. A growing number of
governments have moved to designate Iranian banks, and many
of the world’s leading financial institutions have voluntarily chosen
to reduce or cut ties with Iranian banks.
Iran is ranked 120 out of 183 countries listed in Transparency
International’s 2011 Corruption Perception Index. There is
pervasive corruption within the ruling and religious elite,
government ministries, and government-controlled business
enterprises.
In 2010, the Government of Iran teamed with United Nations
Office on Drugs and Crime to establish a financial intelligence unit
(FIU). The Iranian FIU reportedly will focus on suspicious financial
transactions linked to illicit narcotics proceeds. No entity has been
able to assess whether Iran’s FIU meets international standards.
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| IRAN |
| KnowYourCountry |
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| Last Updated: 2 May 2012 |