On March 20, 2008 the US officially declared war on Iran. A unit within the US Treasury Department, the Financial Crimes Enforcement Network (FinCEN), issued an advisory to the world's financial institutions under the title: "Guidance to Financial Institutions on the Continuing Money Laundering Threat Involving Illicit Iranian Activity."
The US, speaking through FinCEN, is now telling all banks around the world "to take into account the risk arising from the deficiencies in Iran's AML/CFT [anti-money laundering and combating the financing of terrorism] regime”. This provides the rationale FinCEN will now use to deliver the ultimate death blow to Iran's ability to participate in the international banking system.
By managing to get inserted the names of two state-owned banks in the most recent UN Security Council resolution on Iran, the US can now portray the cream of Iran's financial establishment (Bank Melli and Bank Saderat, Iran's two largest banks) as directly integrated into alleged regime involvement in a secret nuclear weaponization program and acts of terrorism.
The US, again through FinCEN, has declared two acts of war: one against Iran's banks and one against any financial institution anywhere in the world that tries to do business with an Iranian bank.
Over the past two years Treasury officials have been crisscrossing the globe to make it abundantly clear in meetings (described by Treasury as opportunities to "share information") with banking and government officials in the world's key financial centers that dealing with Iran is risky business. [Treasury] frequently claims that major European and Asia banks, once they hear the US pitch, freely decided to cooperate with anti-Iran banking sanctions for reasons of "good corporate citizenship" and a "desire to protect their institutions' reputations."
China and Japan "the top two recipients of exports from Iran, together accounting for more than one-quarter of Iran's exports in 2006," according to an analysis of International Monetary Fund (IMF) trading statistics contained in a December 2007 US Government Accountability Office (GAO) report. Airtight global banking sanctions imposed on Iran would presumably make the financial administration of this trade next to impossible.
Will China bend to US sanctions wishes? Early signs suggest the answer is yes.
During a daily press meeting with reporters on March 19, the State Department's spokesperson … questioned rhetorically the wisdom of doing business with Iranian "financial institutions that are under UN sanctions or could become under sanctions if it's found that they are assisting or aiding or abetting Iran's nuclear program in any way." A clearer expression of US desires is hardly possible.
[Excerpt of an article by John McGlynn, ICH]