Sunday, November 20, 2011


On a recent visit to Iran, the Iraqi Army Chief of Staff, Lt. General Babaker Al-Zaibari, met with Mohammed Ali Jafari, a senior leader in the Iran Revolutionary Guard Corps (IRGC). He also held meetings with commanders of the Iranian Air Force and Army.

Press releases regarding his trip, which were full of positive statements attributed to Zaibari, are extremely disturbing, for the US plans on having all its combat troops out of Iraq by 31 December, leaving behind only sufficient security to protect American diplomats and contractors.

If there is going to be close cooperation between the two countries' military in 2012, some of the goods destined for the Iraqi armed forces could end ultimately up in the hands of the IRGC, a sanctioned terrorist organisation. You need to do all that you possibly can to ensure that your bank does not facilitate this. I suggest:

(1) It is suggested that compliance officers at US and EU banks whose clients  are trading with Iranian governmental and military entities ask their legal counsel to prepare an End User Certificate, attesting that Iraq is the final destination for use of the products exported. I suggest that it be prepared in Arabic, with a certified English translation, by an approved translator, and notarised, with an Apostille affixed by the US Embassy or Consulate.

(2) You also should guard against unusually routed payments for goods being shipped to Iraq, for the Iraqi military may not wish to pay for items they will covertly transship to Iran. Watch for atypical source of payment, especially from jurisdictions known to trade with Iran, or assist it in any way in sanctions evasion.

Whilst I am certainly not accusing the Iraqi military of facilitating Iranian sanctions evasion at this time, you need to take precautions, in the event that some elements in Iraq commence cooperative efforts with the IRGC, whether with official approval, or on their own.    

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