The U.S. Treasury Department announced on Wednesday that it sanctioned an Iranian general under the (Narcotics) Kingpin Act for allowing Afghan narcotics traffickers to smuggle drugs through Iran.
Iranian Islamic Revolutionary Guard Corps Qods Force General Gholamreza Baghbani is the chief of a Qods Force office near the Afghan border.
Treasury said he facilitated the smuggling of heroin precursor chemicals and shipments of opium through the Iranian border and into Iran in exchange for moving weapons to the Taliban on his behalf.
It’s the first time the Kingpin Act has been used against an Iranian official, Treasury said in a statement.
“Today’s action exposes [Qods Force] involvement in trafficking narcotics, made doubly reprehensible here because it is done as part of a broader scheme to support terrorism,” said David Cohen, undersecretary of Treasury for terrorism and financial intelligence, in the statement.
It's of little surprise that an Iranian General in the IRGC is trafficking heroin from Afghanistan to support terrorism both is support of actions by the Iranian Government and to support activities of the Taliban. Professionals in both law enforcement and in the AML/BSA/OFAC Compliance field have long held that narcotics traffickers and terrorists have been copying out of each others playbooks... this is just the most recent and most vivid example.
What this does underscore if in but an overly obvious way is that diligence and REALLY knowing your customers and what their business is about is CRITICAL to not running afoul in the Sanctions Compliance arena. Since terrorist, narcotics traffickers and other ne'er-do-well who are not operating in anyone's best interests (other than their own) are not going to fire off a flare gun to identify their locations or activities, understanding the who behind the transaction is more important than ever...
Recent updates to the FATF 40 recommendations emphasize the need for effective Due Diligence as well as a recognition that countries should implement targeted financial sanctions regimes to comply with United Nations Security Council resolutions relating to the prevention and suppression of terrorism and terrorist financing, and that countries should also should implement targeted financial sanctions to comply with United Nations Security Council resolutions relating to the prevention, suppression and disruption of proliferation of weapons of mass destruction and its financing... clearly a recognition that the landscape is continuously changing in the areas of sanctions and AML & CFT Compliance.
So, with 77 updates to the OFAC SDN List in CY2011 and 13 updates so far in CY2012, how are you staying "ahead of the curve" to make sure that your Sanctions Compliance Program is authentically up to par? Is your program performing as it should? Is there a disconnect between policies, procedures and results obtained?
Now is NOT the time to take chances with your program and hope that it will perform as desired. Now is the time to take action and get an Independent Program Review of your Sanctions Compliance Program... Its a small investment in your present and your future.
Shaun Hassett, CAMS is a recognized industry expert in areas of Sanctions Compliance, Due Diligence, AML/BSA Compliance and related business processes associated with identifying high risk entities and in mitigating risks associated with such entities.
(c) 2012 Shaun M Hassett, CAMS Financial Examiantions & Evaluations, Inc.
Wednesday, March 7, 2012
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