News & Events

New Treasury Sanctions Are Unenforceable

WASHINGTON, D.C. — As the U.S. Treasury Department unveiled sanctions against five Iranian individuals Tuesday for providing “ballistic missile-related technical expertise to Yemen’s Huthis,” the Financial Accountability and Corporate Transparency (FACT) Coalition warned that the United States has failed to equip itself with the tools to enforce those sanctions.

Gary Kalman, the executive director of the FACT Coalition, issued the following statement:

“Yesterday, the U.S. Treasury Department issued economic sanctions against five Iranians found to have threatened U.S. national security interests.

“Unfortunately, the U.S. does not have the tools to ensure we can enforce the sanctions.

“The last time we sanctioned Iranian interests, Iran’s government-owned Bank Melli Iran — or National Bank of Iran — established an anonymous shell company to secretly launder money and continued to fund its operations through those investments.

“The National Bank of Iran did not hide its money in another rogue nation.  They set up a shell company in New York and purchased property on Fifth Avenue in Manhattan.  High end tenants paid large rents, unknowingly, to the Iranian government.

“Congress has not updated our laws to prevent such a flagrant violation of sanctions.  Our national security interests remain under threat.  If these individuals want a safe haven to continue business as usual and benefit from returns in the strongest economy in the world, they need only do what their predecessors did and establish an anonymous company in any state to tap into the U.S. financial system.”


Journalist Contact:

Clark Gascoigne
Deputy Director, The FACT Coalition
+1 202 810-1334

Notes to Editors:

  • For more information about the Bank Melli Iran case, reference: United States Department of Justice. “Manhattan U.S. Attorney Announces Court Judgment Finding Midtown Office Building Secretly Owned and Controlled by Government of Iran Subject to Forfeiture for Violations of the Iranian Transactions Regulations and Money Laundering Offenses.” September 17, 2013, available at
  • The U.S. is the easiest place in the world to set up an anonymous shell company to disguise terror financing or hide the proceeds of crime and corruption from law enforcement according to a 2014 study by scholars at Brigham Young University and the University of Texas-Austin. See: Findley, Michael et al. “Global Shell Games: Experiments in Transnational Relations, Crime, and Terrorism.” Cambridge University Press (March 24, 2014), Page 74, available at