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S E C R E T STATE 029096 
 
SIPDIS 
 
 
SIPDIS 
 
E.O. 12958: DECL: 03/13/2033 
TAGS: AS AU BA BR CA CH ECON EFIN EG ETRD EUN FR GM GR
HK, ID, IN, IR, IS, IT, IZ, JA, JO, KNNP, KS, LY, MNUC, MT, MU, NL, 
NZ, PARM, PGOV, PK, PREL, QA, RS, SA, SF, SN, SP, TC, TU, UK, VE, VM, 
YM, EINV, SW 
 
SUBJECT: IMPLEMENTATION OF THE FINANCIAL PROVISIONS OF UNSCR 1803 
 
Classified By: ISN PDAS Patricia A. McNerney 
for reasons 1.4 (b) and (d). 
 
¶1.  (U)  This is an action request.  Please see paragraph 4. 
 
---------------------- 
SUMMARY AND BACKGROUND 
---------------------- 
 
¶2.  (U)  On March 3, 2008, the U.N. Security Council adopted 
Resolution 1803, imposing further Chapter VII sanctions on 
Iran in response to its failure to comply with its 
obligations in UN Security Council resolutions (UNSCRs) 1737 
and 1747, including the obligation to suspend its uranium 
enrichment-related, reprocessing, and heavy water-related 
activities.  Paragraph 10 of the resolution calls upon all 
States to exercise vigilance over the activities of financial 
institutions in their territories with all banks domiciled in 
Iran, in particular with Bank Melli and Bank Saderat, and 
their branches and subsidiaries abroad, in order to avoid 
such activities contributing to proliferation sensitive 
nuclear activities, or to the development of nuclear weapon 
delivery systems, as referred to in resolution 1737 (2006). 
 
¶3.  (U)  On October 25, 2007 the U.S. designated Iranian 
state-owned Bank Melli and Bank Mellat for their support for 
proliferation-related activities under Executive Order (E.O.) 
13382 ("Blocking the Property of Weapons of Mass Destruction 
Proliferators and their Supporters").  (Note: The U.S. 
designated Iran's state-owned Bank Sepah under E.O. 13382 in 
January 2007 for providing support and services to designated 
Iranian proliferation firms.  End Note.)  The U.S. also 
designated Bank Saderat under E.O. 13224 for providing 
support for terrorism.  These U.S. designations of Bank 
Melli, Bank Mellat and Bank Saderat are consistent with the 
provisions of UNSCRs 1737, 1747, and 1803 and FATF guidance 
on Iran.  On March 5, 2008, Treasury Secretary Paulson 
stressed that Iran uses "Iranian, state-owned banks to engage 
in their weapons proliferation, (and) acquisition of missile 
systems...We see all kinds of deceptive practices by Iranian 
banks, so (the U.S. has) been quite aggressive in... singling 
out different Iranian banks for sanctions.  We are continuing 
to work in every country where there are banks that have 
business (with Iran)." 
 
------------------------- 
OBJECTIVES/ACTION REQUEST 
------------------------- 
 
¶4.  (S)  Washington requests Posts deliver the non-papers in 
paragraphs 5 and 6 to appropriate host government officials 
in the foreign affairs and finance ministries.  Posts should 
pursue the following objectives: 
 
FOR ALL ADDRESSEES: 
 
-- Emphasize UNSCR 1803's call for member states to exercise 
vigilance over the activities of financial institutions in 
their territories with all/all banks domiciled in Iran, in 
particular with Bank Melli and Bank Saderat, and their 
branches and subsidiaries abroad. 
 
-- Urge host governments to issue advisories to financial 
institutions in their jurisdiction, informing them of the 
calls for increased vigilance in the UNSCR 1803 and FATF 
statements and emphasizing the growing international 
consensus on the risks of engaging in Iran-related business. 
 
-- Encourage host governments to remind their financial 
institutions that Iran uses a wide variety of deceptive 
practices that make it impossible for financial institutions 
to "know your customer" when dealing with Iran. 
 
-- Request host governments and banking regulators to require 
that banks take measures to ensure enhanced due diligence 
called for by the FATF and the UNSC.  In our view, such 
measures should include senior-level scrutiny of every 
transaction involving Iran, special examination of all 
Iranian accounts, and an executive-level reevaluation of each 
bank's corporate policy toward Iran. 
 
-- Alert governments that Iranian proliferators may 
increasingly use non-designated Iranian banks, including Bank 
Mellat, to facilitate proliferation-related transactions, 
particularly given designation of Bank Sepah in UNSCR 1747 
and the Council's note of caution with respect to Bank Melli 
and Bank Saderat in UNSCR 1803. 
 
-- Recommend that financial regulators consider more thorough 
audits for any regulated financial institution in their 
jurisdiction that continues to do business with Iranian 
related banks and financial entities. 
 
-- Remind governments that the U.S. designated domestically 
Bank Melli and Bank Mellat for their involvement in 
activities contributing to proliferation sensitive nuclear 
activities, including facilitating circumvention of the UNSC 
sanctions on Bank Sepah. 
 
----------------------- ---------------------------- 
------------------- --------------- 
UNCLASSIFIED NONPAPER ON IRANIAN BANKS' DECEPTIVE FINANCIAL 
 
SIPDIS 
PRACTICES FOR ALL ADDRESSEES 
----------------------- ---------------------------- 
------------------- --------------- 
 
¶5. (U)  BEGIN UNCLASSIFIED NONPAPER: 
 
-- We would like to share with you several deceptive 
financial tactics we have seen used by Iranian proliferators. 
 These tactics pose a risk to the security of the 
international banking system and help Iran to circumvent UNSC 
sanctions. 
 
-- Iranian procurement agents for its programs of 
proliferation concern have used front companies and altered 
shipping documents in an effort to support Iran's nuclear and 
missile programs.  These are the most common deceptive 
tactics and ones they have been using to evade export 
controls for years. 
 
-- In addition, when it comes to financial transactions, 
while removing the originator bank's name from financial 
transfers is allowed in some jurisdictions and some 
international banks often bundle transactions for several 
banks together, this method can be used to evade sanctions. 
 
-- Iran appears to be positioning its six private banks to 
replace lost banking operations overseas and to circumvent 
recent U.S. and UN sanctions, partly because Tehran may judge 
that U.S. and foreign actors are less likely to scrutinize 
banks not directly owned by the Iranian government. 
 
-- At least one bank has used a multicurrency account to 
evade payment restrictions and protect assets against 
seizure.  Specifically, in April 2007, a private Iranian bank 
requested a multicurrency account with a foreign bank to 
process international payments in US Dollars (USD), Euros, 
and other currencies.  Multicurrency accounts allow holders 
to deposit funds and make payments in multiple currencies 
from one account, making it easier to evade payment 
restrictions associated with a particular currency and 
therefore protect assets against seizure. 
 
-- Procurement agents' personal bank accounts are being used 
by some UN-designated Iranian defense entities inside Iran to 
finance international purchases, insulating payments from 
international scrutiny.  Many of these agents previously 
received payments into their corporate accounts and may now 
judge that foreign banks will not suspect that transfers from 
personal accounts facilitate UN-sanctioned activity.  Foreign 
banks may not be aware that they are receiving payments from 
Iran's defense industry. 
 
-- Entities tied to the Iranian missile program and Iran's 
Defense Industries Organization (DIO) in 2007 sent millions 
in Euros to a number of different personal accounts in Iran, 
many of which belong to known procurements agents. 
 
-- Iran's Aerospace Industries Organization (AIO) and 
UN-sanctioned Sanam Industrial Group (SIG), the Shahid Hemmat 
Industrial Group (SHIG), and Ya Mahdi Industrial Group (YMIG) 
transferred funds to the Iranian bank accounts of individuals 
affiliated with two missile-procurements companies.  (Note: 
SHIG, SIG, and YMIG were designated in UNSCRs 1737 and 1747 
for their involvement in nuclear or ballistic missile-related 
activities.  End Note).  The procurement agents, who maintain 
offices both in and outside Iran, subsequently transferred 
over half of the funds to banks worldwide, presumably to pay 
for purchases on behalf of Iranian missile entities. 
 
-- In some cases, Iranian entities have combined evasion 
tactics.  For example, Iran's missile program has both 
layered transactions to hide Bank Sepah's role when routing 
funds internationally and used a broker's account inside of 
Iran most likely to make missile-related payments. 
 
-- We urge you to issue advisories to financial institutions 
in your jurisdiction, informing them of the calls for 
increased vigilance in the UNSCR and FATF statements and 
emphasizing the growing international consensus on the risks 
of doing Iran-related business. 
 
-- We encourage you to remind financial institutions in your 
jurisdiction that Iran uses a wide variety of deceptive 
practices that make it impossible for financial institutions 
to "know your customer" when dealing with Iran. 
 
--  We request your government and banking regulators to 
require that banks take measures to ensure enhanced due 
diligence called for by the FATF and the UNSC, including 
senior-level scrutiny of every transaction involving Iran, 
special examination of all Iranian accounts, and an 
executive-level reevaluation of each bank's corporate policy 
toward Iran. 
 
END UNCLASSIFIED NONPAPER. 
 
------------------------- --------------------------- 
---------------------- ----------------- 
LIST OF ALL IRANIAN BANKS DOMICILED IN IRAN, INCLUDING THEIR 
FOREIGN BRANCHES AND SUBSIDIARIES 
------------------------- --------------------------- 
---------------------- ----------------- 
 
¶6.  (U)  BEGIN UNCLASSIFIED LIST OF BANKS: 
 
UNSCR 1803 calls upon all States to exercise vigilance over 
the activities of financial institutions in their territories 
with all banks domiciled in Iran and their branches and 
subsidiaries abroad. 
 
The U.S. encourages host governments to share the following 
comprehensive list of Iranian banks with financial 
institutions to assist their efforts to apply enhanced due 
diligence to Iranian-related financial activity. 
 
The U.S. Financial Crimes Enforcement Network (FinCEN) issued 
an advisory on March 20, 2008 the text of that advisory can 
be found at: www.fincen.gov/ 
fin-2008-a002.pdf. 
 
This list includes banks owned or controlled by the 
Government of Iran, their branches abroad and private banks 
domiciled in Iran. 
 
-- Agricultural Bank (a.k.a. Bank Keshavarzi) - Tehran, Iran 
 
-- Agricultural Cooperative Bank of Iran (a.k.a. Bank Taavon 
Keshavarzi Iran) - Tehran, Iran 
 
-- Agricultural Development Bank of Iran (a.k.a. Bank 
Josiaiyi Keshahvarzi) - Tehran, Iran 
 
-- Arian Bank (a.k.a. Aryan Bank) - Kabul, Afghanistan 
 
-- Banco Internacional de Desarrollo SA - Caracas, Venezuela 
 
-- Bank Josiaiyi Keshahvarzi (a.k.a. Agricultural Development 
Bank of Iran) - Tehran, Iran 
 
-- Bank Kargoshaee - Tehran, Iran 
 
-- Bank Keshavarzi (a.k.a. Agricultural Bank) - Tehran, Iran 
 
-- Bank Markazi Jomhouri Islami Iran (a.k.a. The Central Bank 
of Iran) - Tehran, Iran 
 
-- Bank Maskan (a.k.a. Housing Bank (of Iran)) - Tehran, Iran 
 
-- Bank Mellat - Tehran, Iran 
 
-- Bank Mellat - Seoul, South Korea 
 
-- Bank Mellat - Ankara, Istanbul, Izmir, Turkey 
 
-- Bank Melli Iran - Tehran, Iran 
 
-- Bank Melli Iran - Paris, France 
 
-- Bank Melli Iran - Hamburg, Germany 
 
-- Bank Melli Iran - Central, Hong Kong 
 
-- Bank Melli Iran - Baghdad, Iraq 
 
-- Bank Melli Iran - Muscat, Oman 
 
-- Bank Melli Iran - Al Ain, Deira, Dubai City, Fujairah, Ras 
al-Khaimah, Sharjah, United Arab Emirates 
 
-- Bank Melli Iran Zao - Moscow, Russia 
 
-- Bank of Industry and Mine (of Iran) (a.k.a. Bank Sanad Va 
Madan) - Tehran, Iran 
 
-- Bank Refah (f.k.a. Workers Welfare Bank, f.k.a. Bank 
Refah Kargaran) - Tehran, Iran 
 
-- Bank Saderat Iran - Tehran, Iran 
 
-- Bank Saderat - Paris, France 
 
-- Bank Saderat - Frankfurt, Hamburg, Germany 
 
-- Bank Saderat - Athens, Greece 
 
-- Bank Saderat - Baalbak, Beirut, Saida, Lebanon 
 
-- Bank Saderat - Muscat, Oman 
 
-- Bank Saderat - Doha, Qatar 
 
-- Bank Saderat - Ashgabat, Turkmenistan 
 
-- Bank Saderat - Abu Dhabi, Ajman, Al Ain, Dubai City, 
Sharjah, United Arab Emirates 
 
-- Bank Saderat PLC - London, United Kingdom 
 
-- Bank Saderat Tashkent - Tashkent, Uzbekistan 
 
-- Bank Sanad Va Madan (a.k.a. Bank of Industry and Mine (of 
Iran)) - Tehran, Iran 
 
-- Bank Sepah - Tehran, Iran 
 
-- Bank Sepah - Paris, France 
 
-- Bank Sepah - Frankfurt, Germany 
 
-- Bank Sepah - Rome, Italy 
 
-- Bank Sepah International PLC - London, United Kingdom 
 
-- Bank Taavon Keshavarzi Iran (a.k.a. Agricultural 
Cooperative Bank of Iran) - Tehran, Iran 
 
-- Bank Tejarat - Tehran, Iran 
 
-- Bank Towseh Saderat Iran (a.k.a. Export Development Bank 
of Iran) - Tehran, Iran 
 
-- The Central Bank of Iran (a.k.a. Bank Markazi Jomhouri 
Islami Iran) - Tehran, Iran 
 
-- Europaeisch-Iranische Handelsbank AG (f.k.a. 
Deutsch-Iranische Handelsbank AG) - Hamburg, Germany 
 
-- Export Development Bank of Iran (a.k.a. Bank Towseh 
Saderat Iran) - Tehran, Iran 
 
-- Future Bank B.S.C - Manama, Bahrain 
 
-- Housing Bank (of Iran) (a.k.a. Bank Maskan)- Tehran, Iran 
 
-- Iran Overseas Investment Bank PLC (f.k.a. Iran Overseas 
Investment Corporation Limited) - London, United Kingdom 
 
-- Kargozari Bank Tejarat - Tehran, Iran 
 
-- Mellat Bank DB Aozt (a.k.a. Mellat Bank S/B CJSC) - 
Yerevan, Armenia 
 
-- Mellat Bank S/B CJSC (a.k.a. Mellat Bank DB Aozt) - 
Yerevan, Armenia 
 
-- Melli Bank PLC. - London, United Kingdom 
 
-- Persia International Bank PLC. - London, United Kingdom 
 
Privately Owned Iranian Financial Institutions 
 
-- Amin - Tehran, Iran 
 
-- Bank Pasargad - Tehran, Iran 
 
-- En Bank PJSC - Tehran, Iran 
 
-- Karafarin Bank - Tehran, Iran 
 
-- Novin - Tehran, Iran 
 
-- Parsian Bank - Tehran, Iran 
 
-- Post Bank of Iran - Tehran, Iran 
 
-- Saman Bank Corporation - Tehran, Iran 
 
-- Sarmaye Va Danesh Bank - Tehran, Iran 
 
END UNCLASSIFIED NONPAPER. 
 
------------------ 
REPORTING DEADLINE 
------------------ 
 
¶7.  (U)  Post should report results within one week of 
receipt of this cable.  Please slug replies for ISN, T, 
TREASURY, and NEA.  Please include SIPDIS in all replies. 
 
---------------- 
POINT OF CONTACT 
---------------- 
 
¶8.  (U)  Washington point of contact for follow-up 
information is Michelle New, ISN/CPI, (202) 647-0186, 
newml@state.sgov.gov, or Jennifer Chalmers, ISN/CPI, (202) 
647-9715, chalmersja@state.sgov.gov. 
 
¶9.  (U)  Department thanks Posts for their assistance. 
 
¶10.  (U)  Tripoli minimize considered. 
RICE 
 
 
NNNN 
 



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