List of banks involved in Iranian oil money laundering

The following list of banks involved in Iranian oil money laundering provides a detailed account of financial institutions implicated in schemes designed to help Iran circumvent international sanctions, particularly those targeting its oil exports. These operations often involved complex networks of front companies, deceptive trade practices, and sophisticated financial maneuvers to obscure the origin and destination of funds.

A landmark U.S legal case unfolded from 2017–2019 exposing how Halkbank executives and associates helped Iran bypass sanctions. Turkish-Iranian gold trader Reza Zarrab was arrested in 2016 and later testified in a New York trial that he bribed Turkish officials and worked with Halkbank to launder billions in Iranian oil revenue through gold purchases and fake food shipments.^[9] Zarrab pleaded guilty and became a cooperating witness.^[9] In early 2018, Halkbank's deputy GM Mehmet Hakan Atilla was convicted for his role in the scheme. U.S. prosecutors then indicted Halkbank itself in 2019 on seven counts, detailing how from 2012–2016 the bank conspired with Iranian oil companies to funnel proceeds out of blocked accounts by falsifying records.^[9] The indictment alleges senior Turkish government officials protected the plot and took millions in bribes.^[9] Halkbank has fought the U.S. charges (even appealing to the U.S. Supreme Court on jurisdictional grounds), but the case stands as one of the most prominent prosecutions of a foreign bank for Iranian money laundering.^[9]

In 2022, the U.S. unsealed charges against an elaborate oil-smuggling and money laundering network orchestrated by Iran's Islamic Revolutionary Guard Corps (IRGC) Qods Force.^[10] The indictment named high-ranking IRGC figures (like ex-IRGC commander Morteza Ghasemi) along with Turkish businessmen Sitki Ayan and others who ran an energy conglomerate as a front for Iran.^[10] According to prosecutors, from 2019 onward this network delivered millions of barrels of Iranian oil to buyers in China, Russia, and Syria, then laundered the proceeds through layers of shell companies and fraudulent trade.^[10] Funds were concealed via Turkish companies (Ayan's ASB Group), routed through Oman and Cyprus based intermediaries, and even smuggled as bulk cash or camouflaged as payments for Russian goods.^[10] Notably, about $2 billion of these illicit oil profits transited the U.S. banking system via complex transfers involving a China-based front company.^[10] U.S. authorities also seized $108 million and a shipment of 500,000 barrels of Iranian fuel as part of this operation.^[10]

A major financial investigation culminated in 2014 when BNP Paribas admitted to a decade-long conspiracy to violate U.S. sanctions. From 2004–2012, BNP systematically processed transactions for Iranian oil companies (as well as Sudanese and Cuban entities), deliberately stripping identifying information to evade detectionreuters.comreuters.com. The U.S. DOJ and New York regulators built a case showing BNP executives routed payments through unaffiliated banks and used satellite branches to hide the origin. BNP ultimately pleaded guilty to criminal charges of violating the International Emergency Economic Powers Act (IEEPA) and was sentenced in 2015 to pay $8.9 billion and serve five years probation.^[7] This case, the first guilty plea of a global bank for sanctions violations, was a turning point that put other banks on notice. Internal BNP emails (revealed in the investigation) showed awareness that they were handling "oil dollars" for Iran and Sudan, demonstrating willful misconduct.^[7]

U.S. and UK regulators investigated Standard Chartered for handling Iranian transactions through its branches in the UAE. In 2012, New York's Department of Financial Services accused the bank of scheming with the Iranian regime to hide $250 billion worth of transactions. Standard Chartered settled and later entered a deferred prosecution agreement. When further violations (through 2014) came to light, including dealings with Iranian-controlled companies in Dubai, the bank in 2019 paid another $1.1 billion in penalties reuters.comreuters.com.^[5] A former Dubai-based Standard Chartered banker even pled guilty in a NY court as part of this sanctions case.^[5]

Germany's Commerzbank, the Netherlands' ING Bank, France's Crédit Agricole and Société Générale, Britain's Lloyds, settled U.S. charges in the 2009–2015 period for illicitly moving funds for Iran (often involving oil or petrochemical trade payments). For instance, Commerzbank paid $1.45 billion in 2015 for, among other things, helping Iranian shipping company accounts circumvent U.S. restrictions, and Lloyds TSB paid $350 million in 2009 for falsifying records of Iranian and Sudanese wire transfers. These cases, while not always as large as BNP's, collectively exposed a pattern of global banks laundering Iranian oil earnings by concealing the nature of transactions.^{[11][12][13][14]}

In addition to criminal prosecutions, U.S. authorities have pursued civil actions to seize illicit Iranian oil money. A recent example (2025) is a civil forfeiture complaint for $47 million obtained from the sale of Iranian oil that was masqueraded as Malaysian.^[15] In that scheme, nearly 1 million barrels of Iranian petroleum were sold through a complex fraud: Iran's agents falsified documents and tampered with ship tracking to pretend the oil came from Malaysia, stored it in a Croatian facility under false pretenses, then sold it on the market.^[15] The proceeds, traced to the IRGC, were stashed in foreign bank accounts. U.S. ICE and FBI investigators intercepted those funds (which had briefly passed through U.S. correspondent banks) and filed for forfeiture as property involved in funding a terrorist organization (the IRGC).^[15]

International sanctions, particularly by the United States (and to a lesser extent the EU and UN), form the backdrop that made Iran's oil money laundering both necessary for Tehran and illegal for banks. Key sanctions and actions include:

The U.S. has long prohibited Iran from accessing the U.S. financial system and, since 2010, has enacted secondary sanctions to deter foreign banks from handling Iranian oil revenue. Laws like CISADA (2010) and sections of the 2012 NDAA threatened to cut off any foreign bank from the U.S. market if they knowingly facilitated significant transactions for Iran's oil sector. For example, the U.S. Treasury in 2012 explicitly sanctioned China's Bank of Kunlun and Iraq's Elaf Bank for such activities.^[3] The OFAC (Office of Foreign Assets Control) maintains stringent regulations blocking Iranian government assets and listing Iranian banks, oil companies (e.g. NIOC, NITC), and front companies on the Specially Designated Nationals (SDN) list. Any bank touching these entities' funds risks severe penalties. This legal pressure has led to major enforcement actions: fines against Standard Chartered, BNP Paribas, and others (detailed above) were largely for breaching U.S. sanctions on Iranian oil money.^[4][5] The U.S. also designates networks of facilitators. For instance, in Dec 2022, OFAC sanctioned Sitki Ayan and his Turkey-based network of companies for brokering Iranian oil deals and laundering the proceeds.^[10]

The European Union imposed its own embargo on Iranian oil in 2012 and sanctioned key Iranian banks and entities. EU regulations barred European banks from transferring Iranian oil earnings (except for limited humanitarian trade) and cut off Iranian banks from the SWIFT international payment system. Notably, the EU sanctioned Iran's central bank and major commercial banks, which meant European financial institutions risked penalties for dealing with them. Some European banks' Iran dealings predated the EU embargo or exploited gray areas (like using non-EU subsidiaries), but after 2012 the EU stance hardened. In cases like the Lloyds/Santander front companies in the UK, while those banks weren't directly dealing with an Iranian entity on paper, the fact that Iran's PCC was under sanctions means EU and UK regulations were likely breached if the banks failed to detect the true ownership.^[8] Following the 2015 Iran nuclear deal (JCPOA), the EU lifted many sanctions in 2016, but when the U.S. reimposed sanctions in 2018, many EU companies and banks pulled back from Iran again. The UK, now independently sanctioning Iran post-Brexit, recently fined a UK fintech (Starling Bank) £29 million for lax controls related to sanctions screening.^[16]

While UN sanctions on Iran (prior to 2016) targeted its nuclear and military programs more than oil revenues explicitly, UN designations (e.g. banning Iranian arms exports) indirectly pressured Iran's finances. The UN did call on member states to exercise vigilance over Iranian banks (UNSCR 1929 in 2010), and some of those banks were involved in oil transactions. Additionally, global standard-setters like the Financial Action Task Force (FATF) labeled Iran a high-risk jurisdiction for money laundering and terrorism finance. FATF's warnings urged countries to apply counter-measures, which in practice meant closer scrutiny of any Iran-linked transactions. This international climate made many banks either shun Iranian funds or, in the illicit cases we've discussed, resort to elaborate concealment. Countries like Malaysia and Oman, which did not strictly enforce U.S./EU sanctions, came under diplomatic pressure to cooperate. For instance, the U.S. in 2023 warned that Iran's oil exports were relying on Malaysian-based shippers and urged Malaysia to crack down. Likewise, Gulf states like the UAE and Oman have been pressed by Western allies to tighten oversight of exchange houses and re-export companies that might be aiding Iran.^[17][18]

In recent years, U.S. authorities have aggressively focused on Iran's "shadow banking" networks, the webs of money changers, front companies, and offshore accounts that handle oil revenue outside formal banking channels. In June 2024, the U.S. Treasury sanctioned nearly 50 entities and individuals across Iran, Turkey, UAE, Hong Kong, and elsewhere that formed part of a "sprawling shadow banking network" moving funds for Iran's Ministry of Defense and IRGC home.treasury.gov home.treasury.gov.^[19] These networks used foreign shell companies and exchange houses to launder billions of dollars of oil and petrochemical proceeds for Iran's military apparatus.^[19] By designating these actors, OFAC effectively cuts them off from the global financial system and signals to banks worldwide that facilitating such schemes will have consequences. The U.S. has also used Section 311 of the USA PATRIOT Act to deem jurisdictions or institutions as "primary money laundering concerns". For example, in 2011 Iran's entire financial sector (including the Central Bank) was flagged, and more recently, in 2020 the U.S. designated Iran's financial sector under Executive Order 13902, threatening secondary sanctions on foreign financial institutions dealing with it.^[20][8]

The crackdown on schemes laundering Iranian oil revenues has led to significant legal and financial outcomes:

Several individuals involved in sanctions evasion have been brought to justice. Reza Zarrab, the architect of the Turkey-Iran gold-oil laundering ring, pleaded guilty in U.S. court and became a witness justice.gov.^[1] Mehmet Hakan Atilla of Halkbank was convicted and jailed in the U.S. (later returning to Turkey).^[1] Other co-conspirators in that case, including a former Turkish minister, remain fugitives.^[1] In the IRGC Qods Force network case, while the primary defendants (including Sitki Ayan) are at large in countries that won't extradite, the U.S. has demonstrated its reach by seizing assets and filing charges that could restrict their travel and businesses. ^[1] For the banks, BNP Paribas formally pleaded guilty to criminal charges in U.S. court, an unprecedented outcome that put the bank under probation and compliance monitorship.^[4] Other banks like Standard Chartered and HSBC entered deferred prosecution agreements, essentially admitting wrongdoing and accepting external oversight to avoid indictment.^[21]

Enforcement agencies have levied multibillion-dollar penalties. The $8.9 billion fine against BNP Paribas in 2014 set a record.^[4] Standard Chartered's repeated sanctions breaches cost it over $1.6 billion in total fines (2012 and 2019 combined).^[4] Likewise, other European banks paid hundreds of millions each in U.S. settlements (e.g. ING $619 million, Commerzbank $1.45 billion, HSBC $1.9 billion, though HSBC's was partly for Mexican money laundering, it included Iran sanctions failures). These penalties not only punish past conduct but also fund sanctions enforcement and terrorism victim compensation funds in the U.S.^[4] In the UK, regulators (like the FCA) have also fined banks for sanctions control failures, as seen by the FCA's £102 million fine on Standard Chartered in 2019 for lax due diligence in its UAE operations.^[4]

A direct outcome for many entities caught laundering Iranian oil money is blacklisting via sanctions. Banks like Bank of Kunlun (China) and Noor Islamic Bank (Dubai) essentially lost access to U.S. dollar clearing. Kunlun was formally sanctioned in 2012,^[3] and while Noor Islamic was not individually designated, it shut down Iran operations under threat of U.S. action.^[3] The U.S. has sanctioned numerous Iranian banks (Melli, Mellat, Saderat, Sepah, etc.) and front companies; any foreign bank transacting with them can be cut off from U.S. banks (the so-called "secondary sanctions" penalty). Individuals like Sitki Ayan were added to OFAC's SDN list in 2022, freezing any assets under U.S. jurisdiction and forbidding U.S. or partner institutions from dealing with him.^[19] Similarly, the dozens of firms in the 2024 "shadow banking" crackdown by OFAC are now effectively isolated from legitimate finance.^[19]

Perhaps the most impactful outcome is the disruption of active sanction-evasion networks. Investigations by U.S. Homeland Security, FBI, and Treasury have resulted in the seizure of both funds and physical oil shipments. In addition to the $47 million from the Malaysia-Croatia oil scheme,^[15] the U.S. has seized Iranian oil tankers on the high seas (e.g. the 2020 seizure of 1.1 million barrels from Iranian shipments bound for Venezuela, and a 2021 seizure of an oil shipment off the UAE, proceeds of which, tens of millions of dollars, were forfeited. These enforcement actions deprive Iran of hard currency it desperately seeks from illicit oil sales. They also expose the methods used, from fake documents to ship-to-ship transfers, enabling authorities to tighten loopholes. For example, revelations about Iran disguising oil as Iraqi or Malaysian have led to closer monitoring of those trade routes by international partners.^[15] The UAE has closed certain exchange houses tied to Iran; Malaysia has faced U.S. diplomatic pressure to better police its maritime and financial sectors.^[17] Each major investigation, whether resulting in a trial or not, yields intelligence that helps sanctioning bodies update their regulations and advisories, like FinCEN's advisories on Iranian illicit finance.^[22][23]

The high-profile legal cases and fines have deterred mainstream banks. Most large banks worldwide now enhance sanctions screening and are extremely wary of dealings with Iranian entities. Iran has thus been into more opaque channels (small foreign exchange firms, trading companies, and barter deals). Enforcement outcomes also shows international resolve: U.S. officials regularly share evidence with European and Asian counterparts to spur joint actions. For instance, after the UK front company scandal (Lloyds/Santander) broke, British parliamentarians called for inquiries and stricter controls.^[8] The successes in courtrooms and sanctions lists to date have at least raised the stakes: foreign banks and countries now know that helping Iran bypass oil restrictions can result in severe legal and financial consequences, from billion-dollar fines to being cut off from the global financial network.^[19]

• Money laundering in Iran
• International sanctions against Iran
• Sepehr Energy Jahan
• Financial system
• Oil smuggling in Iran
• China-Iran trade relations