The U.S. Treasury Department disclosed the existence of roughly $9 billion in 2024 financial activity tied to Iranian “shadow banking,” mapping a web of front companies and intermediaries used to sell sanctioned oil, launder illicit proceeds, and procure banned technology.

Drawing on Bank Secrecy Act reports, the department’s Financial Crimes Enforcement Network (FinCEN) outlined FinCEN outlines how Iran-linked entities operated through hubs in the United Arab Emirates, Hong Kong, and Singapore, with shell firms moving the bulk of funds and oil companies accounting for the rest. 

In its Financial Trend Analysis report, the bureau identified 2,027 transactions of $500,000 or more, illuminating flows that passed through U.S. correspondent accounts despite sanctions barriers. 

Key patterns include about $5 billion routed by likely shell companies—largely Hong Kong entities using China-based non-resident accounts—and around $4 billion transacted by oil firms primarily in the UAE and Singapore. 

Shipping and procurement firms received hundreds of millions potentially linked to transporting sanctioned crude and buying controlled technology, while Dubai-based companies were the biggest recipients overall, FinCEN said. 

The bureau cautioned that BSA filings capture only identified suspicious activity and may include attempted or cumulative transactions. 

Read FinCEN’s Financial Trend Analysis report here