Even if a decision to conduct wholesale AML reform is made, years of sanctions have denied Iranian banks the ability to tap the latest in technical expertise in order to bring the industry up to modern standards. The implementation of reform will likely require the help of Western financial experts and a sustained political will in the West to integrate Iran into the global rule-based financial system.
Iran’s stated desire to normalize its banking industry represents a valuable opportunity for the West — specifically strong backers of a global AML regime such as the United States. Beyond the need to show Iranians that their government’s nuclear compromises were worthwhile through a normalization of trade, the United States has an important national interest in strengthening the global efforts against money-laundering and terrorist financing.
Having a large, emerging economy like Iran outside the scope of AML standards does nothing to further American interests. Iran’s current financial officials — motivated by a desire to maximize the gains of the nuclear deal — have already signaled that they need assistance in implementing acceptable AML standards on the ground. It is thus a good time to help Iran emerge from the FATF blacklist in a transparent manner that simultaneously strengthens international efforts against money-laundering and terrorism financing.