Friday, March 21, 2014


Reza Zarrab, under arrest in Turkey

News from a very troubled Turkey this week includes details from a 300-page report, prepared by Turkish prosecutors, alleging a huge organized crime Iran sanctions evasion ring, involving Turkey, China and the UAE. The group, reportedly run by the  Iranian national Reza Zarrab, who holds a Turkish passport under a variation of his name, evaded international sanctions upon Iran, through gold smuggling, and other covert means of wealth transfer.

As the investigation continues, and high-level Turkish government officials are implicated, all the way up to the president himself, who has sought to illegally curb the free press, in a futile effort to control information, compliance officers would be well advised to:

(1) Raise Country risk on Turkey.
(2) Carefully examine all client transactions involving Turkish companies, to avoid any possible unwitting role in facilitating an illegal Iran sanctions violation.
(3) Consider mitigating all your financial exposure in relation to clients engaged in international trade with Turkey, in any form, until you complete Enhanced Due Diligence upon all such customer relationships.

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