The US position is simple: Iran disguises its commercial activities through front corporations that engage in deceptive methods to funnel dual-use goods (products that may have both civilian and military applications, and can be used in illicit WMD and missile programmes) that the US has vowed to interdict.

There is substantial UAE-Iran trade in which to hide dual-use goods, and one must assume that US security services have agents in the region, carefully watching and recording all trade involving the ultimate shipment of goods into Iran.

Prudent MLROs and compliance officers in the region, and in Dubai in particular, should look beyond letters of credit, and require actual customs documents. There is now new technology that allows bankers to profile and identify, on a real-time basis:   

• Abnormal Trade Pricing
• Abnormal Weight Analysis
• Transfer Pricing
• Trade-based Money Laundering

Although outside the scope of this article, should any reader engaged in trade financing not be aware of these resources, kindly send e-mail for the details.  

The unfortunate reality is that there exists a real danger that the US, in its zeal to deter the shipment of technology to Iran that assists its WMD and missile programmes, will mete out sanctions against not only the trading companies involved, but the financial institutions that facilitated payment therefor. Be careful if your clients trade with Iran, as Uncle Sam is watching.