Iran

FATF: Aufruf zum Handeln (schwarze Liste)

The FATF acknowledges Iran’s re-engagement with the FATF as Iran aims to address deficiencies in its AML/CFT regime and calls on Iran to make more progress to address these deficiencies. In June 2016, Iran provided a high-level political commitment to address those deficiencies through an action plan that expired in January 2018. In October 2019, given Iran’s lack of progress on its action plan, the FATF called upon its members and urged all jurisdictions to: require increased supervisory examination for branches and subsidiaries of financial institutions based in Iran; introduce enhanced relevant reporting mechanisms or systematic reporting of financial transactions; and require increased external audit requirements for financial groups with respect to any of their branches and subsidiaries located in Iran. Since February 2020, given Iran’s failure to fully address its action plan, the FATF has called upon its members and required all jurisdictions to apply effective countermeasures in line with Recommendation 19.

In September 2026, Iran provided an update to the FATF on its efforts to address various items of its FATF action plan. Iran has made limited progress on technical compliance by developing a framework to receive international asset freezing requests. However, Iran’s AML/CFT regime continues to have fundamental deficiencies. In particular, Iran’s legal framework does not adequately criminalise terrorist financing and fails to establish a targeted financial sanctions regime in line with the FATF Standards. As a result, the FATF calls on Iran to modify its overarching legal framework, including its primary legislation, to remove any possibility of exceptions, or other limitations, to its terrorist financing offence and targeted financial sanctions regime that are not in line with the FATF Standards and international obligations.

The FATF reiterates its previous assessment and calls on Iran to address its deficiencies regarding Iran’s ratification and domestic implementation of the United Nations Convention against Transnational Organized Crime (Palermo Convention) and United Nations Convention for the Suppression of the Financing of Terrorism (TF Convention). As the FATF noted in June 2026, several of Iran’s reservations to the Palermo and TF Conventions are overly broad and Iran’s domestic compliance with these Conventions is not in line with the FATF Standards. Lastly, the FATF also notes Iran has failed to address the majority of its action plan since 2016. Considering the United Nations Security Council Resolutions related to Iran’s lack of compliance with its nuclear non-proliferation obligations, the FATF reminds all jurisdictions of their obligations under the FATF standards to address proliferation financing risks emanating from Iran. Additionally, given the ongoing terrorist financing and proliferation financing threats emanating from Iran and as Iran’s action plan remains incomplete, the FATF reiterates its call on its members and urges all jurisdictions to apply effective countermeasures on Iran, including the following:

Refusing the establishment of subsidiaries or branches or representative offices of financial institutions and virtual asset service providers from the country concerned or otherwise taking into account the fact that the relevant financial institution or virtual asset service provider is from a country that does not have adequate AML/CFT systems; and

Prohibiting financial institutions and virtual asset service providers from establishing branches or representative offices in the country concerned or otherwise taking into account the fact that the relevant branch or representative office would be in a country that does not have adequate AML/CFT systems.

On a risk basis, limiting business relationships or financial transactions, including virtual asset transactions, with the identified country or persons in the country concerned.

Prohibiting financial institutions and virtual asset service providers from establishing new correspondent relationships and requiring them to undertake a risk-based review of existing correspondent relationships with financial institutions and virtual asset service providers in the country concerned.

When applying countermeasures, countries should ensure that flows of funds involving humanitarian assistance, food and health supplies, diplomatic operating costs, and personal remittances are appropriately handled on a risk basis considering the terrorist financing or proliferation financing risks emanating from Iran, in line with international obligations. Iran will remain on the list of FATF High Risk Jurisdictions Subject to a Call for Action until the full Action Plan has been completed. As the FATF previously stated, should Iran ratify and implement the Palermo and Terrorist Financing Conventions, in line with the FATF standards, the FATF will decide on next steps, including whether to suspend countermeasures. The FATF may consider additional next steps if Iran fails to demonstrate additional progress on its action plan.

The FATF strongly encourages Iran to work with the FATF to urgently make further progress on its action plan to fully address:

1. adequately criminalizing terrorist financing in line with the FATF Standards
2. identifying and freezing terrorist assets in line with the relevant United Nations Security Council resolutions
3. ensuring an adequate and enforceable customer due diligence regime
4. demonstrating how authorities are identifying and sanctioning unlicensed money/value transfer service providers
5. ensure that the ratification and implementation of the Palermo and TF Conventions are in line with the FATF Standards and clarify the capability to provide mutual legal assistance
6. ensuring that financial institutions verify that wire transfers contain complete originator and beneficiary information

Quelle: FATF-Erklärung, Oktober 2026