Sanctions evasion networks pose growing AML challenge

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Global organised crime networks are being used to help Iran evade sanctions and obscure state involvement in illicit financial activity according to an anti-money laundering expert.

Phil Cotter (main picture, inset), chief executive of SmartSearch, said intelligence reports and enforcement records point to a long-established system in which Iran’s Islamic Revolutionary Guard Corps (IRGC) relies on criminal intermediaries to move money, disguise trade and bypass international restrictions.

The networks are used to route funds through shell companies, forged identity documents and cryptocurrency channels, often making Iranian-linked activity appear indistinguishable from conventional organised crime.

Cotter said the patterns closely mirror the types of activity financial institutions, legal firms and property professionals attempt to detect during routine compliance checks.

MONEY LAUNDERING RISK

The structure allows sanctioned regimes to operate indirectly through criminal organisations already experienced in cross-border trafficking, money laundering and financial fraud, providing a layer of plausible deniability.

Cotter said: “I can’t discuss specific SmartSearch customer cases or investigations; however, the public record is extensive. The IRGC has been designated as a terrorist organisation by the US, Canada, Australia, and the entire EU.

“Western intelligence agencies assess that the IRGC systematically uses organised crime to finance operations and evade sanctions, controlling front companies, shipping networks, ports, and financial intermediaries to disguise oil sales, move weapons, and procure restricted goods.”

SANCTIONS EVASION

He added: “There’s documented evidence of IRGC-aligned networks involved in narcotics trafficking from Afghanistan through Iran to Turkey and Europe, overlapping with arms smuggling, human trafficking,and trade-based money laundering.

“Public enforcement actions show shell companies in the UAE and Hong Kong evading petrochemical sanctions, forged identity documents opening accounts across Europe, and cryptocurrency networks facilitating IRGC sanctions evasion.”

CRIMINAL NETWORKS

Cotter said rising geopolitical tensions historically push sanctioned states to rely more heavily on criminal proxy networks.

For UK financial services and property sectors, he added, the warning highlights the need for robust due diligence and stronger scrutiny of complex corporate structures and beneficial ownership.

He said: “What SmartSearch does daily is screen millions of checks across financial services, legal, and property sectors.

“We catch attempts matching these patterns, corporate structures where beneficial ownership doesn’t align with stated directors, forged documents and sanctions screening matches.”

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