About this webinar
The U.S. and Iran have signed a 14-point memorandum of understanding to end the war and reopen the Strait of Hormuz. It opens the door to immediate relief — Treasury waivers on Iranian oil, the release of frozen funds — while deferring the termination of sanctions to a 60-day negotiation. The existing sanctions framework — for now — remains extensive, as do Iran's well-established methods for evading it.
In the months before the MOU, OFAC ran several rounds of designations — hundreds of individuals, entities, and vessels since April — under the "Economic Fury" campaign, a sustained maximum pressure track against Iran.
Last month, 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 Economic Fury operationalized.
While “Economic Fury” is the most visible expression of the pressure leading up to the MOU, it was not the only one. In February, the EU designated the IRGC as a terrorist organization, and the U.K. is advancing legislation to do the same under the Terrorism Act 2000.
This event breaks down two of the primary ways Iran evades sanctions, each 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 f...
