The Financial Crimes Enforcement Network (FinCEN) convened a public-private partnership event in Washington, D.C. bringing together 16 systemically important global financial institutions and federal law enforcement agencies to support efforts to deny Iran access to the global financial system. The session was the first in FinCEN’s “Iran Maximum Pressure and Counter Terrorism” (IMPACT) Exchange series and focused on Iran’s global oil trade and “shadow banking” networks. The exchange was framed as part of the US Treasury’s implementation of National Security Presidential Memorandum-2 and aimed to help financial institutions better understand challenges in complying with US sanctions on Iran and identifying sanctions evasion typologies. Discussions covered how multi-jurisdictional “shadow banking” networks can enable sanctioned Iranian entities to access the international financial system and obscure trade flows, with participants sharing best practices and investigative findings to mitigate abuse linked to illicit finance and terrorism. FinCEN positioned the IMPACT session within its broader FinCEN Exchange program, a statutorily authorized voluntary public-private partnership launched in 2017 and codified under the Anti-Money Laundering Act of 2020.
Financial Crimes Enforcement Network 2025-04-02
Financial Crimes Enforcement Network convenes first IMPACT Exchange with 16 global financial institutions and law enforcement to counter Iran sanctions evasion
FinCEN hosted a public-private partnership event in Washington, D.C., with 16 global financial institutions and federal law enforcement to address Iran's access to the global financial system. Part of the "Iran Maximum Pressure and Counter Terrorism" (IMPACT) Exchange series, it focused on Iran's oil trade and "shadow banking" networks. Discussions aimed to enhance understanding of US sanctions compliance and identify sanctions evasion typologies.