FCC RegUpdate

On May 8, 2024, the Financial Crimes Enforcement Network (FinCEN) issued an advisory concerning Iran-backed terrorist organizations. The advisory aims to assist financial institutions in detecting potentially illicit transactions associated with Islamic Republic of Iran-backed terrorist organizations.

The advisory outlines:

  • • How certain terrorist organizations receive support from Iran.
  • • Various methods employed by these groups to illicitly access or bypass the global financial system for fundraising.
  • • Red flags that may aid financial institutions in identifying suspicious activity related to these organizations.

Red flag indicators concerning the fundraising and money laundering activities of Iran-Backed Terrorist Organizations include:

  • • Transactions involving OFAC-designated entities or linked identifiers, indicating potential sanctions evasion.
  • • Transactions in high-risk jurisdictions with lax AML/CFT practices.
  • • Deals involving front companies or entities with opaque ownership structures that may conceal illicit activities.
  • • Dubious non-profit organizations soliciting donations online, potentially supporting terrorism.
  • • Small cryptocurrency payments from high-risk IPs raising terrorism financing concerns.
  • • Large social media payouts from high-risk IPs suggesting support for terrorism.
  • • Companies incorporated in low-risk locations but operating in high-risk areas, potentially funding terrorism.
  • • Terrorism-linked terms in transaction notes raising suspicion.
  • • Money transfers to risky areas with vague purposes indicating illicit activity.