FinCEN designates Iran as Primary Money Laundering Concern

The US Department of Treasury published the FinCEN note noting Iran “as a jurisdiction of primary money laundering concern”.

This designation comes as part of the implementation of a new Humanitarian Mechanism to Increase Transparency of Permissible Trade Supporting the Iranian People.

The mechanism aim to help the international community performing enhanced due diligence ignorer to ensure that humanitarian trade is not diverted into servicing other sectors of the economy or the Iranian government.

The mechanism enhanced requirements looks to undermine the asset flow to the regime as is noted that: “The Iranian regime oversees a vast network of corruption designed to evade sanctions, generate money for terrorists, and enrich Iran’s clerics,” 

Some implications include the prohibition for US banks to open and/or maintain correspondent banking relationships with Iranian Financial Institutions.



Jaime Prieto

Mr. Jaime Prieto is a lawyer experienced in Financial Crime, Anti-Money Laundering and Counter Terrorism Financing having extensive professional experience in both public and private sectors. Mr. Prieto has been a Head of Compliance in the European Union, the Americas and the Caribbean for banks, trust companies, asset managers, Big Four audit and advisory firms, RegTechs, government agencies and other types of financial professionals. In addition to his experience, he has been legal and educational chair in several compliance and sectorial organisations and performed as a teacher and speaker for a number of organisations and in several local and international forums. Furthermore, Mr. Prieto is an experienced Money Laundering Reporting Officer anda Data Protection officer with additional experience in risk management.
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