About this webinar
On May 19, 2026, OFAC sanctioned Amin Exchange — a major Iranian foreign currency exchange house operating front companies in the UAE, Türkiye, Hong Kong, and China — along with 19 "shadow fleet" tankers moving Iran-origin oil and petrochemicals.
This action marks the latest escalation in the U.S. administration's "Economic Fury" campaign — a sustained maximum-pressure track that has sanctioned more than 100 individuals, entities, and vessels across eight rounds of designations since mid-April.
Days earlier, FinCEN issued an alert detailing the IRGC's use of front companies, financial facilitators, and digital asset infrastructure, instructing SAR filers to flag the activity under the terrorist financing field. The alert is a roadmap of the typologies that the designations are now operationalizing.
Economic Fury is the most visible expression of this pressure, but not the only one. In February, the EU designated the IRGC as a terrorist organization, and the UK is advancing legislation to do the same under the Terrorism Act 2000. For institutions with transatlantic exposure, the architecture matters more than the jurisdiction designating it.
This event will break down the three ways Iran continues to evade sanctions, each now a focus of regulators on both sides of the Atlantic:
Iran’s shadow banking architecture: exchange houses, the “rahbars” (private companies established by Iranian banks), and foreign front companies that keep Iran’s banks tethered to the international financial system.
Illicit oil...
