The leaked documents showed funds belonging to Iranian banks being deposited into accounts outside Iran \u2014 referred to in the records as \u201ctrustee accounts\u201d \u2014 and then moved according to the Iranian banks\u2019 instructions.<\/p>\n
At each stage, identifying details disappeared, leaving foreign banks facing non-Iranian, mostly non-sanctioned trading companies rather than sanctioned institutions such as Bank Parsian, Bank Shahr or Iran\u2019s central bank.<\/p>\n
A May 22, 2023 letter from Bank Parsian showed the bank asking Bank Shahr, another Iranian lender, to arrange the \u201csettlement of purchased dirhams of nominee origin.\u201d<\/p>\n
The letter said Bank Parsian had bought 3.06 million UAE dirhams from Iran\u2019s central bank and that the funds were held in a \u201ctrustee account\u201d at Bank Shahr. It asked Bank Shahr to transfer the money to an account at Banque Misr.<\/p>\n
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A Bank Parsian letter instructed Bank Shahr to transfer 3.06 million UAE dirhams from a trustee account to an account at Banque Misr.<\/p>\n
\u201cWhat keeps the regime\u2019s shadow banking network, the so-called rahbar network, running is not clever financial engineering. It is people: trusted individuals and a handful of sarrafis, the currency brokers who serve as the regime\u2019s gateway to the global financial system,\u201d said Miad Maleki, a former senior Treasury official now at the Foundation for Defense of Democracies think tank.<\/p>\n
\u201cJust as IRGC soldiers carry out the regime\u2019s repression at home, these businessmen and trustees carry the responsibility for funding its terrorism at home and abroad. Without them, Tehran could not move a single yuan out of its accounts in China or buy a single dollar or euro in Dubai or Istanbul,\u201d he added.<\/p>\n
Iran International identified 33 instruction letters in the leaked documents that directed the movement of dirham, yuan and dollars, with a total value of roughly $36 million.<\/p>\n
Dollars made up the largest share of the value transferred, meaning the dominant currency in this shadow network was still the one US sanctions are designed to control.<\/p>\n
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A Bank Parsian letter requesting the transfer of $2.54 million purchased from Iran\u2019s central bank to a foreign beneficiary.<\/p>\n
UAE and China<\/p>\n
The US Treasury described Banque Misr UAE as \u201ca critical node for the Iranian regime\u2019s access to U.S. dollars.\u201d<\/p>\n
Banque Misr was the most frequent UAE destination for Bank Parsian\u2019s foreign transactions, the documents showed, but seven other banks operating in the Arab state also appeared in the records, including some of the UAE\u2019s largest lenders.<\/p>\n
The documents showed the transactions took place between 2022 and 2023, years after Bank Parsian was designated under an executive order targeting terrorism financing.<\/p>\n
Thirteen UAE-registered companies also appeared as beneficiaries across these eight banks. Five of them held the Banque Misr accounts.<\/p>\n
Iran International also identified seven Chinese banks that received money on behalf of Iran.<\/p>\n
The leaked documents include 23 letters from Bank Parsian involving yuan-denominated transactions with Chinese banks, including some of the country\u2019s largest lenders by assets.<\/p>\n
One Chinese bank that specialises in cross-border settlements for small exporters received 11 payment instructions from Bank Parsian according to the documents.<\/p>\n
Most of the beneficiary firms were general trading companies registered in Hong Kong and Singapore, where companies can be established relatively easily, while receiving banking services from mainland China.<\/p>\n
None of the seven Chinese banks identified in the documents has faced US enforcement action over its dealings with Iran.<\/p>\n
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A Bank Parsian letter requesting the transfer of 20.14 million Chinese yuan purchased from Iran\u2019s central bank to a beneficiary account in Hong Kong.<\/p>\n
Tip of the iceberg<\/p>\n
Bessent said in August that the department had “mapped the networks, facilitators, and financial channels that Iran uses to smuggle oil, evade sanctions, and fund terror.”<\/p>\n
President Donald Trump also said in a post on Truth Social that \u201cANY country that allows its financial institutions, businesses, airports, or government entities to provide any type of lifeline to Iran will itself face TREMENDOUS Economic Consequences.\u201d <\/p>\n
His warning included cash transfers, exchange houses and front companies.<\/p>\n
However, U.S. sanctions have tended to focus more heavily on Iran\u2019s oil-revenue and procurement networks than on correspondent banking and trade finance.<\/p>\n
The Iran International investigation reveals the scale of what remains untouched by the US administration. The leaked files show that one Iranian bank, in seven months, directed money to 15 foreign-based banks in two countries through 33 beneficiary companies.<\/p>\n
Out of 33 beneficiaries, only three have been publicly identified by the US Treasury.<\/p>\n
The transactions identified by the investigation were carried out by Iranian financial institutions that were already under US sanctions when the instruction letters were issued.<\/p>\n
Throughout that period, the Iranian institutions at the heart of the network – including the Central Bank of Iran, Bank Parsian, Bank Shahr, Bank Eghtesad Novin, Bank Saman, and Bank Melli – were already under extensive US sanctions. Yet the money continued to move, largely through financial institutions outside Iran.<\/p>\n
Section 311<\/p>\n