On October 23, 2025, FinCEN published a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024. The analysis draws on reports from U.S. financial institutions about transactions before the maximum pressure campaign and supplements FinCEN’s June advisory on Iran’s illicit oil smuggling, shadow banking, and weapons procurement activities.
The FTA aims to help financial institutions monitor and counter Tehran’s shadow banking activity. These networks, spanning the UAE, Hong Kong, and Singapore, use front companies to evade sanctions, launder money, fund military programs, and support regional proxies. Significant findings from the FTA include:
Foreign shell companies operating outside the United States appear to play the largest role in Iranian shadow banking networks;
Iran-linked oil companies transacted billions of dollars, potentially for illicit oil sales; and
Potential technology procurement companies received funds from Iran-linked entities.
Read FinCEN’s press release here.
The full FTA can be found here.