On May 11, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert describing how Iran’s Islamic Revolutionary Guard Corps (IRGC) uses digital assets, front companies and shadow banking networks to evade sanctions and launder the proceeds of illicit oil sales.

The alert is organized around four areas:

• Maritime oil smuggling

• Shadow banking and front company abuse

• Third-country financial facilitators

• Digital asset infrastructure

Crucially, it frames digital assets, and stablecoins in particular, as one leg of a layered structure designed to obscure Iranian involvement, which means cryptoasset exposure often surfaces only through the company and jurisdiction patterns described in the other three areas.

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