The Financial Crimes Enforcement Network (FinCEN) has published an analysis focusing on suspected Iranian shadow banking activities totaling nearly USD 9 billion in 2024. The report is based on information submitted by US financial institutions and focuses on transactions that went through US correspondent banks.
According to FinCEN, Iran uses a complex global network of intermediaries, including foreign exchange houses and front companies, to evade international sanctions. This network aids in the sale of oil and other commodities, as well as the laundering of funds and channeling money for military programs and regional proxy groups. The FTA indicates that many of these entities are operational across the United Arab Emirates, Hong Kong, and Singapore, often using firms related to oil, shipping, investment, or technology industries as fronts.
Highlighting Cross-Border Networks
FinCEN officials emphasized that mapping these shadow networks is vital for understanding how Iran moves money across different jurisdictions. They also noted that the public release of this analysis aims to warn financial institutions about these schemes and promote more rigorous scrutiny of cross-border transactions involving high-risk areas.
The findings suggest that foreign shell companies, which often have no substantial operational presence, were responsible for approximately USD 5 billion of the total activity. Many of these firms operated outside the United States and served as intermediaries for Iran-related financial transactions. Additionally, oil companies linked to Iranian interests accounted for around USD 4 billion in payments, predominantly through entities based in the UAE and Singapore. Another USD 413 million involved entities suspected of aiding in the procurement of export-controlled technology on behalf of Iran.
FinCEN’s analysis aligns with earlier Treasury advisories, including a June 2025 report on illicit Iranian oil trade and weapons procurement networks. These efforts are part of a broader US strategy to restrict Tehran’s access to international financing channels.
