INTERNAL COMPLIANCE MEMO

Türkiye Cumhuriyet Merkez Bankası · BSA/AML

Funds Transfer Authentication & Verification

Compliance Officer / BSA/AML Department in collaboration with TCMB

PURPOSE OF VERIFICATION

This funds transfer is subject to authentication and verification in accordance with:

Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) compliance obligations in collaboration with Türkiye Cumhuriyet Merkez Bankası
Office of Foreign Assets Control (OFAC) sanctions screening requirements under 31 CFR Part 560 (Iran sanctions)
Internal policies on wire transfer fraud prevention and dual approval for large amounts

RATIONALE FOR COMPLIANCE SCRUTINY (Iran‑related risk)

In light of current Treasury/FinCEN advisories on Iranian sanctions evasion and money laundering networks, this transfer has been reviewed for the following red flags:

Beneficiary or intermediary located in or linked to Iran, UAE, Türkiye, or other regional hubs
Payment routed through multiple intermediaries or correspondent banks
Unusually large or inconsistent with customer’s known profile
Vague, incomplete, or suspicious payment reference fields
Links to Iranian “shadow banking” networks, IRGC, or sanctioned banks
Use of false companies, crypto networks, or opaque structures

Finding: No red flags identified – Transfer cleared for processing but detail information required.

5. CONCLUSION

Based on the above verification and screening, this funds transfer is:

Pending further information Request for source of funds / beneficial ownership documentation sent to customer

Dual approval required upon receipt of documents