The Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis identifying approximately USD 9 billion of potential Iranian shadow banking activity that moved through U.S. correspondent accounts in 2024, based on reporting from U.S. financial institutions. The analysis is intended to help institutions detect and counter transactions associated with Tehran’s use of informal and front-company networks to evade sanctions and move funds. FinCEN describes Iranian shadow banking networks as relying on Iran-based exchange houses and foreign companies, connected across continents with prominent nodes in the United Arab Emirates, Hong Kong, and Singapore, and involving a range of Iranian front companies. Key findings highlighted include approximately USD 5 billion in 2024 transactions linked to foreign shell companies operating outside the United States, about USD 4 billion in 2024 transactions by dozens of foreign oil companies that appear to be Iranian front companies (primarily based in the United Arab Emirates and Singapore), and roughly USD 413 million in 2024 transactions involving companies potentially facilitating procurement of export-controlled technology. The Financial Trend Analysis supplements FinCEN’s June advisory on the Iranian regime’s illicit oil smuggling, shadow banking networks, and weapons procurement efforts, and covers transactions occurring before the 4 February 2025 announcement of the maximum pressure campaign against Iran.

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