“The practices involve the use of third-country exchange houses or trading companies that are acting as money transmitters to process funds transfers through the United States in support of business with Iran,” that are not exempted or authorized, the Office of Foreign Assets Control said in an advisory.

In its advisory, the Treasury Department outlined certain scenarios for how financial firms might recognize Iranian abuse of exchange houses and trading companies in an effort to evade sanctions.

For instance, a specific entity may repeatedly attempt to send payments through the United States in apparent violation of U.S. sanctions, or the volume or frequency of payments involving an individual exchange house or trading company indicates an uncharacteristic spike in activity or is inconsistent with the type of business generally conducted.



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