VZCZCXRO0061
OO RUEHBC RUEHDE RUEHDIR RUEHKUK
DE RUEHC #2635/01 3532108
ZNR UUUUU ZZH
O 182100Z DEC 08
FM SECSTATE WASHDC
TO RUEHAR/AMEMBASSY ACCRA IMMEDIATE 3005
INFO IRAN COLLECTIVE IMMEDIATE
RUEHRL/AMEMBASSY BERLIN IMMEDIATE 8729
RUEHLO/AMEMBASSY LONDON IMMEDIATE 1293
RUEHFR/AMEMBASSY PARIS IMMEDIATE 2246
RUEHRO/AMEMBASSY ROME IMMEDIATE 8974
RUEHTV/AMEMBASSY TEL AVIV IMMEDIATE 6703

UNCLAS SECTION 01 OF 02 STATE 132635 
 
SENSITIVE 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: KNNP MNUC IR GM
SUBJECT: IRAN'S ATTEMPTS TO EXPAND BANKING RELATIONSHIPS 
IN GHANA 
 
REF: A) STATE/TREASURY/EMBASSY ACCRA EMAILS- 12/02/08 
 
¶1.  (U) This is an action request.  Please see paragraph 
seven. 
 
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SUMMARY 
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¶2.  (SBU) Representatives in the Iranian government have met 
with counterparts in the Ghanaian government to discuss the 
opening of an Iranian bank in Ghana.  Given Iran's attempts 
to evade UNSC sanctions, the establishment of an Iranian bank 
in Ghana could potentially threaten the integrity of the 
Ghanaian banking system and provide Iran a new conduit to 
circumvent UN Security Council sanctions.  The U.S. urges 
Ghana to deny Iran's requests to open a bank in Ghana and to 
subject Iranian activities to increased scrutiny, as called 
for by the international community. 
 
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BACKGROUND 
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¶3.  (SBU) Press reports throughout 2008 have noted that Iran 
is actively working to expand its banking relationships with 
Ghana.  The bank will be a joint venture between the Iranian 
Chamber of Commerce and the Ghana Chamber of Commerce, as 
part of a larger effort by the Iranian government to expand 
its ties and influence in Africa.  Governments should 
exercise increased vigilance regarding financial and 
commercial relationships with Iranian entities that may be 
associated with Iran's proliferation sensitive nuclear 
activities, in particular to ensure full compliance with 
UNSCRs 1737, 1747 and 1803. 
 
¶4.  (SBU)  UN Security Council resolutions 1737, 1747, and 
1803, adopted under Chapter VII of the UN Charter, contain 
several finance-related provisions.  Resolution 1737 requires 
UN Member States to prevent the provision to Iran of 
financial services related to the transfer, manufacture or 
use of the prohibited items described in that resolution. 
All three resolutions also require UN Member States to apply 
targeted sanctions to entities and individuals designated in 
the resolutions for their involvement with Iran's 
proliferation-sensitive nuclear activities or ballistic 
missile program.  Member States are required to prevent the 
provision of financial assets or economic resources to or for 
the benefit of designated individuals/entities, and to freeze 
their assets as well as those of entities "owned or 
controlled" by them or persons/entities acting on their 
behalf (operative paragraph 12 of UNSCR 1737).  In addition, 
UNSCR 1803 calls on all member states to exercise vigilance 
over the activities of financial 
 institutions in their territories with banks domiciled in 
Iran, in particular Bank Melli and Bank Saderat, and their 
branches and subsidiaries abroad. 
 
¶5.  (SBU) On October 16, 2008, the Financial Action Task 
Force (FATF) issued its fourth warning on the serious threat 
posed by Iran's lack of a sufficient anti-money laundering 
and counterterrorist financing regime. The statement noted 
particular concern by Iran's lack of effort to address the 
terrorist financing risk and reinforced the call for 
jurisdictions to implement preventative measures to protect 
their financial sectors from this risk. 
 
¶6.  (SBU)  In addition, FATF has issued guidance on 
implementation of UNSCRs, most recently on UNSCR 1803's call 
for enhanced vigilance regarding Iranian banks, including 
their branches and subsidiaries abroad, to protect against 
the proliferation finance risk posed by Iran. The FATF 
guidance, among other things, encourages jurisdictions to 
implement risk mitigation practices with transactions, 
accounts and relationships with Iranian banks.  The U.S. has 
urged jurisdictions to implement the FATF guidance on 1803 
and take preventative measure that include denying any 
requests by Iranian financial institutions to enter into 
joint ventures or to establish a subsidiary, branch or 
representative office in their jurisdiction.  As other 
countries take additional action to protect their financial 
 
STATE 00132635  002 OF 002 
 
 
systems from Iranian abuse, Iran is seeking new jurisdictions 
in which to operate.  Allowing this Iranian activity in Ghana 
would introduce increased risks for the Ghanaian banking 
system.  It would also significantly increa 
se the burden on Ghana's implementation of UNSCRs and FATF 
standards. 
 
¶7.  (SBU) The European Union adopted laws in November that 
apply Community-wide measures related to the implementation 
of UNSCR 1803.  This regulation calls for continued vigilance 
over account activity relating to money laundering and 
financing of terrorism and requires Bank Saderat to notify 
each Member State's financial authority of all transfers of 
funds carried out or received by them within their 
jurisdiction within five working days of the transaction. 
 
¶8.    (SBU) As part of the FATF recommendations, countries 
need to have measures in place to protect themselves from 
jurisdictions of concern.  Ghana's ability to protect its 
financial system from jurisdictions of concern, such as Iran, 
will be evaluated during its upcoming mutual evaluation 
assessment scheduled for April 2009. 
 
¶9.  (SBU) Executive Order 13382 allows for the designation of 
firms or individuals which are found to be working for or on 
behalf of entities already designated.  This E.O. provides 
the authority for the assets of any person in violation of 
the E.O. to be blocked and prevents the transfer, export, 
withdrawal of these assets.  If any Ghanaian firms or 
individuals are found to be working for or on behalf of 
entities designated under U.S. Executive Order 13382, they 
may be designated themselves. 
 
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OBJECTIVES/ACTION REQUEST 
------------------------- 
 
¶10.  (SBU) Washington requests Post draw from the summary and 
background in paragraphs 2-8 to address these concerns with 
appropriate host government officials in the foreign affairs 
and finance ministries.  Post should pursue the following 
objectives: 
 
-- Seek clarification and more details on press reports that 
Iran and Ghana are seeking to establish a joint venture bank 
in Ghana. 
 
-- Inform the GOG that the establishment of an Iranian bank 
could threaten the integrity of the Ghanaian financial system 
and increase the burden on Ghana to implement international 
standards and protect its financial system from jurisdictions 
of concern such as Iran. 
 
-- Inform the GOG that the European Union has recently 
implemented regulations calling for enhanced vigilance over 
Iranian account activity relating to money laundering and 
financing of terrorism and requires Bank Saderat to notify 
each Member State's financial authority of all transfers of 
funds carried out or received by them within their 
jurisdiction within five working days of the transaction. 
 
-- Urge Ghana to refuse Iran's request to open a bank in 
Ghana and to subject Iranian financial activities to 
increased scrutiny, as called for by the international 
community. 
 
-- Encourage the GOG to warn Ghanaian financial institutions 
about the risks of doing business with Iran. 
 
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REPORTING DEADLINE 
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¶11.  (U) Post should report results as soon as possible. 
Please slug replies for ISN, T, TREASURY, AF and NEA.  Please 
include SIPDIS in all replies. 
 
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POINT OF CONTACT 
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¶12.  (U) Washington point of contact for follow-up 
information is Kevin McGeehan, ISN/CPI, (202) 647-5408, 
McGeehanKJ@state.sgov.gov. 
 
¶13. (U) Department thanks Post for its assistance. 
RICE