The United States Financial Crimes Enforcement Network has issued an alert to help financial institutions identify and disrupt funding streams and procurement networks supporting Iran’s Islamic Revolutionary Guard Corps. The alert explains that the IRGC launders proceeds from illicit oil sales through shell and front companies, exchange houses, multi-jurisdictional shadow banking networks and digital asset channels, and provides red flags to support suspicious activity detection and reporting. The release says the IRGC uses a shadow fleet of vessels, forged or relabeled shipping documents, third-country blending, and front company bank accounts outside Iran to disguise the origin of oil and move funds through the international financial system. Examples of red flags include shipping companies with Iranian counterparties, attempts to obscure vessel information, ownership or oil origins, unusual use of exchange houses, unusual digital asset payments by petroleum, shipping, trading or trust companies, and activity involving unregistered peer-to-peer exchangers, foreign-located money services businesses or nested digital asset service providers. The alert also notes that stablecoins and Iran-based or international digital asset service providers can form part of these structures, while the release reiterates that persons, vessels and foreign financial institutions facilitating illicit Iranian oil trade risk U.S. sanctions, including possible secondary sanctions.

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