On October 15, FinCEN issued an alert providing red-flag indicators to help financial institutions detect and report potential abuse of religious charity networks by the Iranian regime, including the diversion of religious tithes, known as “khums.” According to the alert, which was issued as part of Operation Economic Outcast, the regime has a “long history” of using charitable and religiously affiliated organizations to fund domestic repression, enrich regime elites and support violence abroad. The alert noted that in some cases, organizations acting on behalf of regime-linked ayatollahs or the Supreme Leader collect khums and may move the funds to Iran or Iran-linked actors through hawalas, cash couriers and other informal channels.

The red-flag indicators include: (i) charities that solicit donations but provide no apparent charitable services or that openly support the regime; (ii) large donations from unknown sources that are quickly transferred to other charities; (iii) structuring or other efforts to evade currency transaction reporting requirements; and (iv) recipients with no clear connection to the charity that cash out or forward the charity’s transfers. FinCEN encouraged institutions to report potential sanctions violations to OFAC and to include the key term “FIN-2026-IRANCHARITYABUSE” in Field 2 and the narrative of any related suspicious activity reports. FinCEN also noted that legitimate charities should retain access to financial services and urged institutions to take a risk-based approach to customer due diligence.