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Subject: Bank Secrecy Act/Anti-Money Laundering
Date: May 1, 2008
To: Chief Executive Officers, BSA Officers, and Compliance Officers of All National Banks; Federal Branches and Agencies; Department and Division Heads; and All Examining Personnel
Description: Guidance to Financial Institutions on the Continuing Money Laundering Threat Involving Illicit Iranian Activity
On March 20, 2008, the Financial Crimes Enforcement Network (FinCEN) issued guidance to supplement information previously provided to financial institutions on serious deficiencies existing in the anti-money laundering systems of the Islamic Republic of Iran.
The guidance follows the February 28, 2008, statement issued by the Financial Action Task Force (FATF) reiterating its concern about continuing deficiencies in Iran's anti-money laundering and combating the financing of terrorism (AML/CFT) system. In addition, on March 3, 2008, the United Nation's (UN) Security Council passed Resolution 1803 (UNSCR 1803), calling on all states to exercise vigilance over activities of financial institutions in their territories with all banks domiciled in Iran and their branches and subsidiaries abroad. The FATF statement, combined with the UN's specific call for vigilance, illustrates the increasing risk to the international financial system posed by the Iranian financial sector, including the Central Bank of Iran.
The guidance urges financial institutions to take into account the risk arising from the deficiencies in Iran's AML/CFT regime, as well as all applicable United States and international sanctions programs, with regard to any possible transactions with the Iranian institutions listed in the advisory.
Ann F. Jaedicke