Countries and businesses should be extremely careful about doing any business with Iran due to the significant U.S. sanctions risks. The Islamic Revolutionary Guard Corps, designated by the United States as a Specially Designated Global Terrorist, controls large portions of the Iranian economy. Anyone doing business with Iran should conduct enhanced due diligence on all commercial transactions and relationships and understand the significant risks involved.
Support for Terrorism: Iran is the world’s leading state sponsor of terrorism, and the Iranian regime uses a network of proxy groups to conduct terrorist acts on Iran’s behalf. The Islamic Revolutionary Guards Corps – Qods Force (IRGC-QF) and Ministry of Intelligence and Security (MOIS) directly support terrorist groups that have killed hundreds of civilians and government officials worldwide.
- The Iranian regime funds and facilitates terrorist activity by exploiting the international financial system.
- All countries that support the cause of peace and stability in the Middle East and around the world should take appropriate steps to block Iranian actors that support terrorism from abusing the international financial system.
- U.S. companies with ties to entities continuing to do business in Iran should be aware of the risk that their business could be indirectly facilitating Iranian support for terrorism, given the expansive role the IRGC plays in Iran’s economy. Unknowing facilitation of terrorism can still be unlawful, so U.S. companies should maintain strong due diligence and “know your customer’s customer” programs.
Iran Exploits its Neighbors’ Financial Systems: The United States sanctioned 14 IRGC-linked targets in May 2018 for conducting illicit financial activities in neighboring countries to funnel money to the IRGC, including nine targets abusing the United Arab Emirates’ financial system by running a large-scale currency exchange network with the support of the Iranian Central Bank, and four targets abusing Iraq’s financial system.
Iran Fails to Uphold International Financial Obligations: The Financial Action Task Force (FATF), the international standard setting body for anti-money laundering and counter terrorism financing, has repeatedly highlighted Iran’s failure to meet its international obligations and called on countries to “advise their financial institutions to apply enhanced due diligence…to business relationships and transactions with natural and legal persons from Iran.”
Iranian Commercial Airlines Support IRGC: The United States sanctioned Iranian commercial airline Mahan Air in 2011 for providing financial, material, and technological support to the IRGC-QF. Mahan has facilitated the IRGC-QF’s military operations in Syria by conducting hundreds of flights from Tehran to Damascus since 2012. Every country that permits Mahan Air to fly to its airports should understand Mahan Air’s history of violating international civil aviation norms, and every company supporting Mahan should know they run the risk of incurring U.S. sanctions.
- Since 2018, the United States has designated 10 entities supporting Mahan Air’s activities, including front companies procuring spare aircraft parts for Mahan; general sales agents (GSAs) providing services to Mahan in Malaysia, Thailand, and Armenia; and an Iranian airline, Qeshm Fars Air, that helps Mahan Air facilitate the IRGC-QF’s malign activities.
Additional information on U.S. efforts to disrupt Iran’s illicit financial networks: