A brief recapitulation of America's recent Iranian banking sanctions is in order:

• Bank Saderat Iran (BSI), blacklisted on 9 September, 2006, for alleged funds transfers to terrorist organisations.
• Bank Sepah, sanctioned on 9 January 2007, for its alleged participation in Iranian missile and nuclear weapons financing.

Who is next?  Perhaps these Iranian institutions, all of whom have facilities in Europe: 

• Bank Melli
• Bank Mellat
• Bank Tejarat

MLROs and compliance officers should take advantage of what may constitute an advance warning, and check their list of correspondent banking relationships for the names of these banks, as well as any branches or subsidiaries with slightly different or deceptively similar names, and to forward the information to supervisory bank officers, for an immedate risk assessment. UK readers should take particular note of banks there owned by the above-mentioned Iranian banks, as some have different names. 

Please understand that though there has been no published information regarding any alleged or possible criminal activities of these institutions, sanctions may be instituted against Iranian banks without notice by the United States, given the current political and military situation. Prudent compliance officers anticipate such action, and prepare their staff accordingly.