FinCEN Updates Iran Alert

On June 6, 2025, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an 18-page advisory (FIN-2025-A002) detailing Iran’s illicit financial activities, including oil smuggling, shadow banking, and weapons procurement. This advisory supersedes the 2018 version, providing updated insights and red flags for financial institutions.

Key Updates:

• Oil Smuggling Operations: Iran employs a “shadow fleet” of aging vessels to clandestinely transport oil, often disabling tracking systems and falsifying documentation to evade detection.

• Shadow Banking Networks: Complex financial networks involving exchange houses and front companies are used to launder proceeds from oil sales and finance weapons procurement.

• Weapons Procurement: Revenue from illicit oil sales funds the acquisition of weapons components and dual-use goods, often through falsified documentation and transshipping via third countries.

Concurrent Sanctions:

Simultaneously, the Office of Foreign Assets Control (OFAC) designated over 30 individuals and entities linked to Iranian nationals involved in laundering billions through shadow banking mechanisms. 

Implications for Financial Institutions:

The Alert includes a "Reminder of Relevant BSA Obligations and Tools for U.S. Financial Institutions," advising financial institutions to reference “IRAN-2025-A002” in Suspicious Activity Reports (SARs) related to these activities.

The complete advisory, including detailed red flags and guidance for compliance, is available on FinCEN’s official website. [link]