FinCEN Alert on the Use of Front Companies, Financial Facilitators, and Digital Asset Infrastructure by Iran’s Islamic Revolutionary Guard Corps to Evade Sanctions and Launder Proceeds (FIN-2026-Alert002)

Financial institutions are requested to reference the key term "FIN-2026-Alert002" in SAR field 2 and narratives when filing suspicious activity reports related to actors suspected of funding or facilitating procurement networks for the Islamic Revolutionary Guard Corps. The alert details typologies involving front companies, layered corporate structures, and digital asset infrastructure used to obscure beneficial ownership and launder proceeds from sanctions evasion, including approximately $4 billion in oil transactions and $5 billion moved by shell companies in 2024. It highlights the use of stablecoins, such as USDZ, and unregistered peer-to-peer exchangers to circumvent traditional financial systems and notes that Iranian digital assets activity has reached billions of dollars annually.

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See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t).
For more information about the IRGC, see Director of National Intelligence (DNI) National Counter Terrorism Center
(NCTC), “Islamic Revolutionary Guard Corps (IRGC)” (“Mar. 2025 NCTC IRGC”) (Mar. 2025).
See Mar. 2025 NCTC IRGC, supra note 2; Congressional Research Service (CRS), “Iran: Background and U.S. Policy”
(updated May 22, 2025), at p. 4.
The IRGC, including the IRGC-QF, was designated as an FTO in April 2019. See Department of State, “Designation of
the Islamic Revolutionary Guard Corps” (Apr. 8, 2019).
See FinCEN, FIN-2025-A002, “FinCEN Advisory on the Iranian Regime’s Illicit Oil Smuggling Activities, Shadow
Banking Networks, and Weapons Procurement Efforts” (“June 2025 FinCEN Iran Advisory”) (June 6, 2025). FIN-2026-Alert002 May 11, 2026 FinCEN Alert on the Use of Front Companies, Financial Facilitators, and Digital Asset Infrastructure by Iran’s Islamic Revolutionary Guard Corps to Evade Sanctions and Launder Proceeds The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) is issuing this Alert to assist financial institutions1 in identifying actors suspected of funding and facilitating procurement networks supporting the Islamic Revolutionary Guard Corps (IRGC) and mitigating those risks through the filing of suspicious activity reports (SARs).2 The IRGC was created after the Iranian Revolution as a parallel organization to Iran’s regular armed forces that reports directly to Iran’s Supreme Leader and is charged with defending the Iranian regime. The IRGC includes ground, naval, and air forces, along with the Basij internal security militia, and the IRGCQods Force (IRGC-QF). The IRGC-QF conducts covert operations abroad and supports terrorism by supplying funding, training, and weapons to aligned groups.3 Since its inception, the IRGC has engaged in terrorist activity with the support of the Iranian government and is a designated Foreign Terrorist Organization (FTO).4

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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works