HOW TO CONTROL AND PREVENT MONEY FROM IRAN GETTING INTO YOUR BANK  AND/OR FINANCIAL INSTITUTION?

FROM A
DIFFERENT POINT OF VIEW by Monte Friesner

Financial Crime Consultant for WANTED SA

Saturday October 09, 2010

WANTED SA through one of intelligence groups have exposed a group operating in ten (10) countries around the globe and based in London, England who have created a complex concept using Visa, MasterCard, eCommerce under the disguise of a software company; breaking sanctions and assisting citizens, residences and others in Iran to move money effectively and undetected until discovered about 2 months ago.

A full and thorough investigation was started involving several Law Enforcement groups in many countries to combat this threat that started about 6 years ago with so called students from Iran living abroad in the USA, Spain, Australia, Turkey, UK, EU and New Zealand. (More on this story to follow)

One of the most pressing issue facing Compliance Officers in 2010 is the problem of how to effectively comply with the Comprehensive Iran Sanctions, Accountability and Divestment Act (CISADA) and to avoid regulatory fines and penalties, and resulting reputational damage.

As we all recognize and know; there are two problems!

First, there's no complete and accurate list of all the correspondent relationships between the sanctioned Iranian Banks, and Banks located throughout the world.

Second, the majority of the large number of business entities who trade with Iran are not themselves sanctioned, and therefore, are unknown to Compliance Officers at International Banks unless they are discovered.

So what's the solution?  

This week, WANTED SA announced that it has started its Iran Economic Interest (IEI) solution. This product has two elements:

• *       The WANTED SA  IEI Database, which is an extremely effective tool for automatically screening clients, client relationships, and transactions, for individuals or entities that are believed to have a direct and/or indirect or a third party relationship with Iran.
• *       The WANTED SA IEI IntegraScreen Report, which is a bespoke due diligence report on any individual or entity that could potentially have a relationship with Iran.  

Given the requirement of CISADA that financial institutions can incur civil or criminal liability for failure to properly manage Iran risk through information that should have been known, proper risk management demands that such open-source information be reviewed in evaluating and identifying potential Iran sanctions evaders, who are seeking to utilize the services of your bank. Banking best practices now has a new meaning, at least for the purposes of Iran sanctions.

With the potential risk of what may be massive fines and penalties, levied by regulatory agencies and law enforcement, upon banks who are found to have facilitated sanctions evasion, it is strongly suggested that you review the rules of the sanctions and contact WANTED SA for information and/or names of groups that are operating with Iran.

Many countries around the world including Russia, EU, Australia, and Canada are cancelling orders and forsaking millions of dollars of profit in order to comply with the Sanctions against Iran contrary to the money hungry and greedy individuals who breach the sanctions and break the laws until they are caught, convicted and sentenced to prison. Even Insurance companies are taking actions against the shipping companies in Iran and doing their part

At present Iran is a danger to all of us living in this world and until Iran curtails or forsakes its illicit exploration of Nuclear Weapons according to the findings of the United Nations and the USA; we all have a responsibility to assist in all means to stop the flow of money for Iran.    

The facts and opinions stated in this article are those of the author and not those of WANTED SA. WANTED SA does not warrant the accuracy of any facts and opinions stated in this article; does not endorse them, and accepts no responsibility for them.