While EU governments make a mad dash to open new business relationships with Iran, in light of the gradual removal of sanctions, compliance officers at Western banks whose customers contemplate lucrative new contracts there should take note that an Iranian millionaire has been sentenced to death for corruption. Given the teeth in Western countries' foreign corruption laws, it would be prudent to see that bank clients do not go down the slippery slope of making payments to officials, to facilitate business.
To avoid embarrassing, and probably expensive, corruption charges, compliance officers at financial institutions should initiate some form of micro-managing monitoring client payments to Iran, to show that the maximum effort was mad to prevent payments to corrupt Iranian officials, or their nominees. Western companies must not be allowed to funnel illegal bribes and kickbacks to Iranian government staff, to generate business. If uncovered, Iran's response could be as public as this week's announcement that one of its businessmen would be put to death for corruption. Govern yourselves accordingly, to avoid not only fines and possible indictment, but reputation damage. Let's not let your bank clients pell-mell rush to gain new business in Iran result in a corruption scandal.