On June 6, 2025, FinCEN issued an Advisory to assist U.S. financial institutions in identifying and reporting potential sanctions evasion and other suspicious activity related to Iran. The Advisory supports President Trump’s maximum pressure campaign against Iran and replaces FinCEN’s 2018 Advisory on the Iranian Regime’s Illicit Activities.
Through the advisory, FinCEN provided updated red flags and information on current trends and typologies for Iranian sanctions evasion and other illicit activity, including oil smuggling, “shadow banking” networks, and weapons procurement. These red flag indicators include the following:
Red Flags Associated with Illicit Oil Smuggling and Sales
Documentation associated with a customer’s oil shipping-related transactions is inconsistent with information contained in maritime database entries used for conducting due diligence. For example, a maritime database may indicate that a vessel called in an Iranian port, even though this information is not included in the shipping documents submitted to financial institutions for payment processing.
Documentation associated with a customer’s oil-related transactions makes reference to vessels that, according to maritime databases, have undergone recent or multiple name or flag changes, or transfer of ownership or operation to another person following OFAC’s designation of its owner or operator, but the designated owner or operator appears to maintain an interest in the vessel.
Documentation associated with a customer’s oil-related transactions makes reference to vessels that claim an International Maritime Organization (IMO) number that, on examination of maritime databases, belong to a different vessel or to vessels that have previously been scrapped.
Documentation associated with a customer’s oil-related transactions makes reference to “Malaysian blend” oil, particularly if the vessel is bound for China by way of Southeast Asia and if maritime databases indicate that the vessel displayed AIS irregularities during its voyage or reveal evidence of a ship-to-ship transfer in proximity to Southeast Asia.
Transactions involving a petroleum or shipping company reveal that it does business with counterparties that have ties to Iran or transports goods using vessels that have ties to Iran or that maritime databases indicate have made stops at Iranian ports.
A customer makes oil-related transactions and wire transfers involving vessels that have been previously linked to suspicious financial activities or that include documentation, such as bills of lading or shipping invoices, with no consignees, that appear to be falsified, or that omit key information, in an attempt to hide the Iranian nexus.
Red Flags Associated with Iranian Shadow Banking Networks
A customer makes transactions that move through multiple exchange houses and/or trading companies, adding additional fees and costs as the transactions progress, where the fees, number of transactions, and pattern of transactions do not reflect standard and customary commercial practices.
An exchange house or trading company in a jurisdiction in close geographical proximity to Iran uses forged or falsified documents to conceal the identity of parties involved in transactions that will utilize regional banks’ correspondent banking relationships with U.S. financial institutions to access U.S. dollars.
A customer receives wire transfers or deposits that do not contain any information about the source of funds, contain incomplete information about the source of funds, or do not match the customer’s line of business, especially if they involve entities in a high-risk jurisdiction for Iranian illicit finance-related activity.
A general trading company registered in a commercial free trade zone in the UAE with opaque ownership and whose trading counterparties are companies mostly located in Singapore and Hong Kong has bank accounts at multiple UAE financial institutions.
A company based in Hong Kong, that banks using a Chinese non-resident account, has little to no web presence, is co-located with numerous other similar companies, or is recently incorporated yet transmitting large payments with no adequate explanation for the source of funds, makes numerous payments in large figures to UAE general trading companies with no clear business purpose.
Red Flags Associated with Iranian Weapons Procurement Networks
A customer makes transactions involving companies that originate with, or are directed to, entities that are general trading companies, suspected front companies, or companies that have a nexus with Iran. Other indicators of possible front companies include opaque ownership structures, individuals/entities with obscure names that direct the company, or business addresses that are residential or co-located with other companies, especially companies that have been previously sanctioned.
A customer declares information about the nature of its business that is inconsistent with other available information, such as previous transaction history or associated transactional information, particularly if trade data indicates that they have a history of facilitating shipments to and from Iran and if they transact predominantly with technology companies or chemical suppliers.
A customer makes transactions that are directed to companies that operate in unrelated businesses, and which do not seem to align with the customer due diligence (CDD) and other customer identification information collected during client onboarding and subsequent updates. For example, and of note with regard to illicit Iranian financial activity, customers that primarily receive funds from commodities trading companies, but send funds primarily to electronics suppliers.
Multiple companies incorporated at roughly the same time share counterparties, addresses, owners, or name similarities and demonstrate similar transaction profiles. Such companies may have little to no web presence and transact in large, recurring amounts.
A company based in the Middle East with links to Iran or that shows indications of being a front company receives payments primarily from petroleum companies and then makes payments primarily to electronics companies based in Hong Kong and China.
The full Advisory can be found here.
