FinCEN issued this advisory to help U.S. financial
institutions (particularly banks; money services businesses (MSBs), such as virtual currency
administrators and exchangers; and dealers in precious metals, stones, and jewels) better detect
potentially illicit transactions related to the Islamic Republic
of Iran (Iran)
Of the 21 point list of red flags, the last three pertained to virtual currencies.
- Logins from Iranian Internet Protocol Addresses or with Iranian Email. Internet Protocol (IP)
login activity from entities in Iran or using an Iranian email service in order to transact virtual
currencies through a virtual currency exchange. In such cases, financial institutions may also
be able to provide associated technical details such as IP addresses with time stamps, device
identifiers, and indicators of compromise that can provide helpful information to authorities.
- Payments to/from Iranian Virtual Currency Entity. A customer or correspondent payment to
or from virtual currency exchanges that appear to be operating in Iran.
- Peer-to-Peer (P2P) Exchangers. Unexplained transfers into a customer account from multiple
individual customers combined with transfers to or from virtual currency exchanges. Wire
transfers are usually associated with funding an account or withdrawing value, especially
with foreign exchanges that may operate in multiple currencies.
Source : Fincen[pdf]