The forced resignation of James Freis, the Director of FinCEN, was rumoured to have occurred due to his reported failure to move swiftly on Iran sanctions evasions issues. Now, the appointment of a senior Justice Department official with both seizure expertise, and experience prosecuting what the agency describes as "professional money launderers" serving international organisations, means that FinCEN is expected to make a greater contribution to America's recent focus on banks that facilitate Iran sanctions evaders. She is expected to assume her new position in September.
Jennifer Shasky Calvery was the chief of the DOJ Asset Forfeiture & Money Laundering Section, which reportedly seizes over $1.5bn annually. Look for increased cooperation between FinCEN, US law enforcement agencies, and other Federal and state regulators, in their campaign against financial institutions that assist Iran in its circuitous methods of evading international sanctions against its prohibited Weapons of Mass Destruction and ballistic missile programmes.
It would be prudent to assume that seizures of US assets of foreign banks accused of facilitating illicit Iranian transactions will now increase. Many major foreign banks have US branches, subsidiaries, agencies, and representative offices, whose accounts are vulnerable to seizure by US law enforcement agencies. Additionally, correspondent accounts of foreign banks, located within US financial institutions, can also be forfeited. Since literally every major foreign financial institution has access to the US financial structure, their US assets are at risk if they violate Iran sanctions.