On October 23, FinCEN released a new Financial Trend Analysis identifying approximately $9 billion in potential Iranian shadow banking activity that flowed through U.S. correspondent accounts in 2024. The analysis, based on Bank Secrecy Act filings from U.S. financial institutions, found that Iran leveraged complex networks of exchange houses and foreign front companies to evade sanctions, sell oil and other commodities abroad, launder money, and fund its military and weapons programs.

FinCEN found that Iranian shadow banking networks operated internationally across jurisdictions — including the United Arab Emirates, Hong Kong, and Singapore — using firms involved in oil trading, shell companies, shipping companies, investment companies, and technology procurement companies, to move funds internationally, facilitate sanctions evasion, and support Iran’s military and nuclear programs. FinCEN noted that foreign shell companies that existed only on paper played the largest role, moving approximately $5 billion, while Iran-linked oil companies transacted $4 billion, and companies facilitating technology procurement received an estimated $413 million.

The analysis supplemented FinCEN’s June advisory on Iranian illicit oil smuggling and shadow banking and followed from President Trump’s February announcement of a “maximum pressure campaign” against Iran.