Reliable sources, responding to our article* dealing with Iran's recent authorisation, given to private oil brokers, to sell Iranian oil on the international market, have stated that at least 50% of Iran's oil production is being diverted to adjacent Iraqi Kurdistan, where it is being refine alongside Iraqi oil. Thereafter, it is sold on the international market, and listed as being of Iraqi origin, thereby effectively evading international sanctions.
Canadian nationals experienced in the petroleum industry are alleged to be the central players in this operation. Given the fact that the refined Iranian-origin petrol is reportedly co-mingled with the Iraqi production, identification of national origin becomes an impossibility.
Under those circumstances, compliance officers at international banks whose clients are engaged in the purchase of petrol from Kurdish refineries would be well advised to obtain affidavits from both the clients and then refineries, to the effect that no oil of Iranian origin is contained in any shipment. Whilst this is not a foolproof guarantee, such precautions, if implemented, appear to rise to the level of best practices. Have your clients visit the refinery facility to make a visual confirmation of non-Iranian origin, if this is feasible.
*Seeking to Evade Sanctions, Iran Authorises private Oil Exports