WATCH FOR IRANIAN SANCTIONS EVASION THROUGH GEORGIA

Though pro-Western Georgia maintains close ties with the United States, and aspires to eventually join NATO, its proximity to Iran, and its need to find resources and trading partners outside of Russia, have resulted in the expansion of Iranian diplomatic facilities in Georgia, and the abolishment of visa restrictions upon Iranian nationals. Iranian tourists are reportedly a common sight in Georgia, Although one does wonder if any of them are actually IRGC* Quds Force agents.

Most sources have seen evidence of the reluctance of Georgian banks to open accounts for Iranians, but the expansion of trade and tourism will give Iranian companies more access to the Georgian financial system. Whilst there has been no evidence uncovered thus far,  implicating Iranian entities in the use of banks in Georgia to evade international sanctions, sources indicate that the use of Georgian front companies and individuals has occurred. Moreover, there is a large complement of Iranian Georgians, who still speak their native language, through whom trade sanctions evasion could potentially be facilitated, should Iran "request" their assistance and cooperation.

Note well that Iranian oil is openly transported through Georgia, to Black Sea ports, where it can be shipped out to end users, thereby evading existing global sanctions against Iran. Given that geography has given Georgia a hostile and powerful neighbor to the north, it is reasonable to assume that, without a consistent Western presence, the country will encourage ties with Iran, to ensure its survival. These will include international trade.

Therefore, it is suggested that you be alert to the following:

(1) Have you seen any unusual financial transactions involving your clients and Georgia's banks ?
(2) Has the volume of your clients' trade with Georgia, especially involving food items, increased ? Remember, Georgia has only 4,000,700 people.
(3) have any of your clients shipped technical items to Georgia that could be considered dual-use products useful in Iran's sanctioned WMD and ballistic missile programmes ?
(4) Do you have any Georgian expats trading, high volume, to their home country ?
(5) Are any of your bank clients receiving funds from foreign banks located in Georgia ?

If any of the above answers is positive regarding a customer, it is suggested that you immediately conduct an Enhanced Due Diligence investigation, to rule out trade with Iran.
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* Iran Revolutionary Guards Corps.