The purpose of UANI’s banks campaign is threefold: to identify the international operations of Iranian banks, to highlight the illicit activities of these banks, and to urge banking authorities around the world to take action.
Though their activities are ostensibly commercial, Iranian banks and their subsidiaries are deeply integrated with the Islamic Revolutionary Guard Corps (IRGC), critical in facilitating Iran’s nuclear program, and act as an essential source of funding for the Islamic Republic’s terrorist proxies. In many cases, prominent Iranian banks are under direct ownership of the IRGC—the vast majority are sanctioned by the United States under various designations including the proliferation of weapons of mass destruction (WMD) and support for the IRGC. Given the IRGC’s dominance over Iran’s economy, there is no way of ensuring if any Iranian bank can operate outside of IRGC influence and objectives. Additionally, Iranian banks have been accused of money laundering and other financial crimes, particularly in the Middle East and Latin America. Ultimately, Iranian banks and their illicit activities pose a significant threat to both international security and financial stability.
Despite United States sanctions, G7 Financial Action Task Force’s (FATF) 2020 decision to blacklist Iran—and continually re-asserting Iran’s status as one of only two “High-risk Jurisdictions,” along with North Korea—and damaging reports on the role of banking in sanctions evasion, Iranian banks continue to operate freely, under the license of Central Banks and regulatory bodies, in more than 50 countries worldwide. These include not only Iran’s partners, like Russia, but important U.S. allies, like the United Kingdom, France, Germany, and Italy. Critical global financial hubs, including London, Frankfurt, and Hong Kong, all continue to host Iranian banks. This has continued even as the JCPOA (Iran Nuclear Deal), which led to the lifting of restrictions on Iranian banks, has become all but defunct, and as their respective governments have ramped up sanctions on other Iranian entities. All FATF member-states are obliged to implement FATF calls for diligence and ‘countermeasures’ against Iranian banks and to observe US secondary sanctions—yet operations continue.
The threat posed by Iranian banks is not limited to Western countries. In Lebanon, Iranian banks have maintained a central role in providing funds to Hezbollah, which have been used to purchase arms, maintain power in the country, and conduct terrorist operations. Other countries where the IRGC conducts similar malign activities, like Bahrain, Georgia, and Venezuela all have a significant Iranian banking presence. Immediate and decisive action is possible, as shown by the Iraqi government’s recent decision to revoke the operating license of Iran's largest bank. With greater awareness and pressure, similar actions can and should be taken by other banking authorities.
Following UANI’s previous efforts to deny Iranian banks access to SWIFT, demonstrate the involvement of Iranian banks in Hezbollah’s money laundering activities, and limit Iran’s ability to print currency, this banks campaign is an important step in curtailing Iran’s access to the global financial system and mitigating the effects of money-laundering, terrorist financing, and proliferation of financing of WMDs (ML/FT/PF).
UANI’s Terror Banks Campaign calls on relevant banking authorities to investigate, penalize, and suspend Iranian banks for their illicit activities. See the below Map for information on Iranian foreign bank branches:
