On October 15, 2026, FinCEN issued an Alert asking financial institutions to report potential Iranian regime abuse of religious charity networks, including diversion of religious tithes, or khums. This action is part of Treasury’s Operation Economic Outcast, which targets Iran and its financial enablers.
According to the Treasury’s press release, the Iranian regime has exploited religious organizations and khums payments from the global Shi’a community to enrich elites, suppress dissent, and support terrorism and other destabilizing activities. FinCEN’s Alert highlights how these funds may be transferred through informal channels, including hawalas and cash couriers, and provides red flags to help financial institutions detect, prevent, and report suspicious activity.
The Alert also listed the following red flag indicators to help financial institutions detect, prevent, and report suspicious activity potentially involving Iran’s abuse of religious charity networks, including when Iran’s direct involvement is not readily identifiable in transaction details:
A customer that is a charitable organization or NPO solicits donations but does not appear to provide any charitable services or openly supports the Iranian regime or its terrorist proxies, such as in fundraising appeals or on social media.
A customer that is a charitable organization or NPO receives large donations from an unknown source over a short period of time and then sends significant wire transfers or checks to other charitable organizations or NPOs.
A customer that is a charitable organization or NPO, or an employee, officer, or contractor of a charitable organization or NPO, engages in a pattern of behavior suggesting efforts to evade the Currency Transaction Report (CTR) reporting requirement (e.g., alters or cancels a transaction when advised a CTR would be filed or engages in structuring with multiple cash transactions in amounts below $10,000), as well as avoiding recordkeeping requirements.
A customer receives transfers from a charitable organization or NPO with which the customer has no clear business relationship and then proceeds to withdraw the funds in cash or remit them onward.
Read the Treasury’s press release here.
The Alert can be found here.
