FinCEN flags $9 billion in Iranian shadow-banking activity, citing SARs filings from U.S. banks
By 
Oscar Gonzalez2025-11-05T18:35:00
Approximately $9 billion of potential shadow-banking flows tied to Iranian networks in 2024, according to a new analysis from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). The report highlights how illicit funds are making their way through financial institutions as they meet the requirements of the Bank Secrecy Act (BSA).
FinCEN’s Financial Trend Analysis (FTA), entitled ”Iranian Shadow Banking: Trends in Bank Secrecy Act Data” that was released last month, was based on suspicious activity reports (SARs) filed by U.S. financial institutions with FinCEN between February 2024 and July 2025, for transactions made in 2024. The FTA includes 2,027 transactions totaling roughly $9 billion that had nexis to Iran.
The report states Iranian entities moved billions of dollars in revenue from the sale of sanctioned oil abroad, which gets routed through U.S. correspondent accounts through the use of foreign shell companies. These funds are disguised behind legitimate-looking transactions as they make their way into U.S. financial institutions.
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