Reliable reports from the Middle East state that Iran, unhappy with a visit to Saudi Arabia by the senior Hamas leadership, which based in the Gulf country of Qatar, is now sending US Dollars, literally in suitcases, to Hamas in Gaza, to support its terrorist activities. So who is passing it all those greenbacks ?
It is obviously either Kurdish banks, or bankers in Baghdad; both groups have a long history of sourcing dollars for Iran, with little or no interference from the United States, which sees both groups as supposed allies, and does not want to rock the boat, by calling its "allies" on terrorist financing charges. You probably find that to be repugnant, but American foreign policy often trumps both anti-money laundering, as well as terrorist financing, for short-term goals that later turn out to be a mistake.
Therefore, as the compliance officer at an international banks with correspondents in either the Kurdish region, or the capital of Iraq, you may want to ask yourself: have any of these banks lately increased their demand for bulk dollars, and is there no visible business reason for those requests ? If so, you may want to inquire further, lest you get hit with an OFAC civil money penalty, by the next US administration, for facilitating terrorism.
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