A governmental source in the Republic of Panama has confidentially disclosed to me that Venezuelan nationals have formed more than seven hundred companies there, and are using them for the sole purpose of trading with Iran, thereby efficiently evading international sanctions against Iran. All the corporate formation, and associated legal work, is being performed by the same lawyers each time.
This is a major pipeline through which important industrial and commercial goods are purchased for Iran, which is the end user not disclosed to sellers of goods, who are led to believe that they are destined for Latin America, specifically Venezuela and Panama.
The companies then make deposits in two major Venezuelan banks, and obtain Letters of Credit in Panama from those banks' Panamanian subsidiaries. After all the goods are sold and delivered to solely Government-controlled Iranian entities and agencies, the funds are wired into Panama to pay off the Letter of Credit. Neither the original manufacturer or wholesaler is aware of the illegal final destination of their products, nor are any regulatory agencies, in any country where either is located, alerted to the violations.
If the Venezuelan and Panamanian banks involved will not now terminate their relationships with the sanctions evaders, and discharge the bankers who are involved in approving this business, they will sustain major reputation damage, plus possible US criminal indictment of senior officers and owners, when they are identified in a public forum. Additionally, their US subsidiaries and/or correspondent relationships are at serious risk of revocation and termination, or even the loss of access to the American financial structure, pursuant to US Treasury Department regulations.
Assuming that you are a compliance officer at a Canadian or American bank with customers who engage in international trade:
(1) Do you have any bank clients who are selling goods to Panamanian companies ?
(2) Does your division have the necessary databases that allow you to identify, or rule out, whether your customers' customers are Venezuelan nationals ?
(3) Do you have sufficient back-up information sources to verify the identities of all the parties?
If you cannot satisfactorily answer the above, then you could be unwittingly facilitating illegal Iranian Weapons of Mass Destruction or Ballistic Missile programmes. I will answer any specific questions that you may have about (2) and (3) upon request. (email@example.com).