FinCEN Issues Advisory On Iranian "Shadow Banking" Network

On June 6, 2025, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an advisory (the Advisory) to assist U.S. financial institutions in identifying and reporting potential sanctions evasion and other suspicious activity related to Iran. As we discussed in a recent Blog post, the Trump administration has renewed its "Maximum Pressure Campaign" against Iran, as detailed in President Trump's National Security Presidential Memorandum-2 (NSPM-2). In April 2025, FinCEN kicked off a public-private partnership information exchange series aimed at thwarting Iran's ability to lead and sponsor terrorism. The information exchange series focuses in part on Iran's "shadow banking" system — a network of multi-jurisdictional illicit financial systems that facilitates revenue streams of sanctioned Iranian entities.