In June 2016, Iran committed to address its strategic AML/CFT deficiencies and made decision to seek technical assistance in the implementation of the Action Plan. Since 2016, Iran established a cash declaration regime, enacted amendments to its Counter-Terrorist Financing Act and its Anti-Money Laundering Act, and adopted an AML by-law.

In October 2019, the FATF called upon its members and urged all jurisdictions to: require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran; introduce enhanced relevant reporting mechanisms or systematic reporting of financial transactions; and require increased external audit requirements for financial groups with respect to any of their branches and subsidiaries located in Iran.

Iran’s action plan expired in January 2018. In February 2020, the FATF noted Iran has not completed the action plan

In February 2020, the FATF noted that there are still items not completed and Iran should fully address:

1. adequately criminalizing terrorist financing, including by removing the exemption for designated groups “attempting to end foreign occupation, colonialism and racism”;
2. identifying and freezing terrorist assets in line with the relevant United Nations Security Council resolutions;
3. ensuring an adequate and enforceable customer due diligence regime;
4. demonstrating how authorities are identifying and sanctioning unlicensed money/value transfer service providers;
5. ratifying and implementing the Palermo and TF Conventions and clarifying the capability to provide mutual legal assistance; and
6. ensuring that financial institutions verify that wire transfers contain complete originator and beneficiary information.

Now, given Iran’s failure to enact the Palermo and Terrorist Financing Conventions in line with the FATF Standards, the FATF fully lifts the suspension of counter-measures and calls on its members and urges all jurisdictions to apply effective counter-measures, in line with Recommendation 19.

FATF GAFI INTERPRETIVE NOTE TO RECOMMENDATION 19 (HIGHER-RISK COUNTRIES)

Iran will remain on the FATF statement on High Risk Jurisdictions Subject to a Call for Action until the full Action Plan has been completed. If Iran ratifies the Palermo and Terrorist Financing Conventions, in line with the FATF standards, the FATF will decide on next steps, including whether to suspend countermeasures.
Until Iran implements the measures required to address the deficiencies identified with respect to countering terrorism-financing in the Action Plan, the FATF will remain concerned with the terrorist financing risk emanating from Iran and the threat this poses to the international financial system.