Who is FATF Restricting?

The bill that had been on the agenda of the tenth parliament after eight years of discussion and suspension has been suspended again amid threats and uproar. In recent months, the four bills aimed at combating money laundering and preventing the financing of terrorism have become a battleground for the government and its supporters against opposing political and military groups. The peak of these disputes has been over joining the implementation of the regulations of the Financial Action Task Force (FATF). One of the four bills that President Hassan Rouhani's government sent to parliament at the end of May, coinciding with the end of the suspension period for Iran on the FATF blacklist, included Iran's accession to the Convention on the Financing of Terrorism, amendments to the Money Laundering Law, and amendments to the Law on the Financing of Terrorism. The executive branch's action was aimed at reaching an agreement with this international group, under which it committed to resolving its issues related to money laundering and terrorism financing, and in return, the group suspended restrictive measures against Tehran until mid-June. According to former Minister of Economy Ali Tayebnia, negotiations with this group had been seriously on the agenda of the government and the Supreme National Security Council since 2009. The efforts of Rouhani's government are also a continuation of the interactions and decisions of Mahmoud Ahmadinejad's cabinet and the Supreme National Security Council. The importance of removing Iran from the blacklist lies in the fact that when a country is on this list, it is unable to conduct financial and banking transactions with other countries. These restrictions primarily affect the citizens of countries on the blacklist. For instance, this year, in two cases, the accounts of several Iranians in Georgia and China were closed due to 'non-compliance with FATF regulations.' However, government opponents claim that the approval of these bills is 'colonial' and a form of 'banking capitulation.' They believe these bills pave the way for Western countries to dominate Iran's financial and banking information and affect domestic and foreign policymaking. Additionally, they argue that the conditions stipulated in the regulations of the special action group and the Palermo Convention hinder Iran's support for resistance groups such as Hezbollah in Lebanon and Hamas in Palestine, as well as Ansar Allah in Yemen. Especially since Hezbollah and Hamas are listed as terrorist organizations by some countries. However, the definition of terrorism by Iranian officials and some other countries differs profoundly. But this is not the whole story. Groups close to military and political power institutions in Iran are concerned that with the establishment of financial transparency, there will be no way to circumvent sanctions. Therefore, they interpret compliance with the four anti-money laundering bills as 'self-sanctioning.' During Mahmoud Ahmadinejad's presidency, the IRGC's overseas networks, such as the Quds Force and figures close to military and security institutions at the top of the government, conducted financial and banking transactions through intermediaries. Now, with Iran's accession to international treaties, all international transactions must be transparent, effectively restricting these officials' ability to circumvent new sanctions imposed by the U.S. against Iran. On the other hand, these international conventions require member countries not to engage in transactions with entities and individuals on the sanctions list. This obligation, in addition to recommendations regarding the high risk of transactions with Iran, is significant. The Basel Governance Research Institute reported in 2016 that Iran had the highest 'money laundering risk' for three consecutive years among 149 countries. Adhering to these obligations and recommendations primarily restricts the IRGC and numerous companies affiliated with Astan Quds Razavi, the Imam Khomeini Relief Foundation, the Mostazafan Foundation, the Executive Headquarters of Imam's Command, and other institutions close to the top of the power pyramid, which have numerous economic activities in various domestic and foreign sectors. Many individuals and companies associated with them are on the sanctions list. For instance, last September, Bank Mellat and Bank Sepah refrained from providing foreign exchange services to the Khatam al-Anbia Headquarters and a company affiliated with it, citing foreign sanctions. Concerns about the restrictions on the IRGC's economic activities have reached a point where recently, Sasan Shah Vaisi, a professor at Imam Hussein University, warned in a video interview with 'Economic Ninety' about joining FATF, stating: 'With its implementation, we will have to dissolve the IRGC. The IRGC and its components are in the crosshairs.' Hassan Rouhani also, without directly referring to the IRGC's economic activities, emphasized last December, opposing the 'friendship bank,' that banks must be both 'Islamic and modern' and 'compatible with all the regulations and rules that exist in the world's banks. If we do these things, we will be one step away from that blacklist.' The Rouhani government is trying to compensate for the failure of the JCPOA after the U.S. withdrawal from the agreement by regaining the trust of other countries for investment in Iran. The economic and diplomatic team of the cabinet is seeking to push back the shadow of accusations of Iran's support for terrorism; they have even promised to accept FATF with conditions and a detailed interpretative statement to appease their opponents. However, so far, the power of military and political institutions opposing the government has been greater. They have resorted to any means to maintain their political position, even threatening the lives of representatives who support joining the FATF. Maintaining political and economic positions is a matter of life and death.