• Reg52
  • Posts
  • Iran Oil EU & US payments deep-dive & Outstanding IRS SAR results

Iran Oil EU & US payments deep-dive & Outstanding IRS SAR results

Author

Paul Huston
March 31, 2025

Mon 31 March 2025

Good morning

  1. Main Story: DoJ $47m Iran Oil forfeiture - I went deep to create a hopefully a flow/sketch that's hopefully useful for your internal chats

  2. Regulatory Updates: Very impressive SAR related results from the IRS

  3. Enforcement Actions & Fines: Four main AML reasons for a UK Gambling fine - useful to highlight need for specific controls

  4. Request for comment: FinCEN reporting reqs around Correspondent Banking & Iran 

1. Main Story: Iran Oil Forfeiture - touching European & US Payments systems

United States | DoJ

Over the weekend, I went deep into the 23-page DoJ release on the $47M Iran Oil forfeiture (DoJ) and created the flow/diagram below:

This originated from a conversation with a subscriber who said they wanted content that: 

  1. Would keep internal teams laser-focused on evolving FinCrime risks, and 

  2. Would help with FCC business cases to tackle them 

I believe this approach meets those needs (and the subscriber found it useful), but I’d appreciate your thoughts. Let me know if it works for you or if there’s anything you’d adjust.

2. Regulatory Updates: SAR success from IRS

United States

IRS

  • Impressive results as IRS Criminal Investigation team releases FY24 metrics and announces it will provide feedback on SARs (IRS)

    • Used BSA data (across fiscal years 2022-24) to

      • Identify $21.1 bn inn fraud tied to tax and financial crimes

      • Seize $8.2 billion in assets tied to criminal activity

      • Obtain $1.4 billion in restitution for crime victims

    • 87% of IRS’s criminal investigations recommended for prosecution had a primary subject with a related BSA filing

    • IRS to start providing feedback to FIs

      • “The program will ensure that financial institutions receive quantifiable results from IRS-CI on how the agency uses suspicious activity reports (SARs) to investigate federal crimes. As part of this program, IRS-CI will also streamline subpoena requests and share pointers with financial institutions on what to include in SARs to maximize impact”

FDIC

  • FDIC rescinds previous guidance (FIL-16-2022 - Notification of Engaging in Crypto-Related Activities) and FDIC-supervised institutions can now engage in permissible crypto-related activities without receiving prior FDIC approval (FDIC) 

US Treasury/OFAC

  • OFAC designated five individuals and three companies supporting the Hizballah finance team - also has an Iran angle (US Treasury)

Europe

  • Guardian reported that European chiefs agreed not to lift Russian Sanctions - it looks like the US may impose secondary tariffs too (Guardian)

UK

FCA

  • FCA launches single portal (My FCA) for UK FIs fulfilling regulatory obligations (down from three) (FCA)

    • Jessica Rusu the FCA's chief data, intelligence and information officer reiterates commitment to being “a smarter regulator” and “easier to engage with”

Australia

  • AUSTRAC highlights that some crypto ATM providers may not have the right AML and CTF checks in place (AUSTRAC)

    • Not too surprising, but what is interesting is the growth in Crypto ATM providers in Australia that AUSTRAC highlights:

      • Australia has the highest number of crypto ATMs in the Asia Pacific region

      • Huge growth:

        • 2019: 23 Crypto ATMs

        • 2022: 60 Crypto ATMs

        • 2025: 1,600 Crypto ATMs

  • Today is also the day that changes to tipping off offence come into effect in Australia (AUSTRAC)

    • Old legislation was 20 years old, now focussed on the harms that could flow from a disclosure

3. Enforcement Actions & Fines

UK

Gaming Commission

  • Football Pools Limited faces £375,000 regulatory action (Gambling Commission)

  • Four main reasons for the AML component:

  1. AML policy was overly reliant on financial triggers to identify when customers present higher ML or TF risks

  2. Processes in place at the time of the assessment did not automatically apply hard stops when AML thresholds were reached and were only applied when resulting manual reviews took place. 

  3. Manual reviews did not always occur promptly, which meant that hard stops were not put in place in a timely manner, if at all

  4. Officials noted that there were incidents of delays in the creation of customer risk profiles, incidents where risk profiles had not been created, and incidents where risk profiles were not completed for a significant period (on average 25 days after the financial trigger was hit).

United States

DoJ

  • DoJ secures forfeiture of $5m related to workers union based in Dorchester, Massachusetts, which was defrauded out of $6.4 million after it received a spoofed email that appeared to be from its investment manager (DoJ)

4. Request for Comment

FinCEN invites requests to comment related to proposed renewal without change of correspondent banking and Iranian-linked FI reporting requirements (Federal Register)

  • Need to add comments by May 27, 2025

Have a great week.

Paul