Ms Mandelka emphasised the importance of the financial sector in assisting in the fight against illicit actors (including criminals, terrorists and proliferators) that threaten global security by furthering their illicit aims.
In her tour of the region she was looking to help enhance controls and inform leadership of steps to be taken collectively to inhibit bad actors. More specifically to counter Iran’s malign activities in the region and improve AML defenses of companies and governments in relation to such activities.
Following Donald Trump’s decision to withdraw the US from the JCPOA (Joint Comprehensive Plan of Action) the US are intent on building a global coalition with governments, including the UAE. This is to counter Iran’s destabilising activity and their financing of terror and address its proliferation of missiles and advanced technology.
They are very intent on applying “unprecedented financial pressure” on the Iranian regime. All previous sanctions are reimposed subject to 90 day and 180 wind down periods.
A core part of the US strategy is highlighting “deceptive Iranian business practices”. Iran has systematically exploited the global finance system. Their tactics include forging documents, obfuscating data and hiding illicit activities under official cover of government entities. The Central Bank of Iran is facilitating the flow of financing to the Quds forces.
Recent examples include:
1. Millions of US dollars were channeled through the Iraqi Al Bilad Bank, to the Quds forces. The Central Bank of Iran coordinating this. Valiollah Seif, the central bank of Iran governor has been designated as a result as well as his deputy and the Chairman of the bank.
2. Iran also managed to procure and transfer millions of US dollars from Iran and the UAE using an network of exchange houses. The was again facilitated by the Central Bank of Iran through providing licenses and documentation. The network was designated and shut down.
3. It has also been discovered that they have facilitated the counterfeiting of currency by purchasing printing machinery and supplies in Europe to print counterfeit Yemeni currency.
4. Turkish front companies were used to purchase airline aviation parts for Iranian airline Mahan Air and other designated airlines.
The US are encouraging all participants in the financial services sector to maintain a high level of alert as companies are being put at risk of US sanctions through their unwitting involvement. Those that seek to do business there (in Iran) do so at their own risk.
All companies are urged to take additional steps with regards to Iran. Asking for more information to identify front and shell companies. Everyone should look at all counterparties associated with any closed accounts and any shared characteristics.
There is also a need to continue to develop information sharing. Everyone is encouraged to review the FinCEN advisory notices on a regular basis
https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets
https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets
HOLT consultancy can assist you with client onboarding, AML and sanctions training and client file reviews. If you would like help, please email HOLT consultancy using info@holtconsultancy.com or call +971 4 386 6360.
