If you weren't watching all the tumult in northern Iraq this week, you may not have noticed that President Barzani, of the Kurdistan Regional Government, has bluntly stated that the time is ripe for the autonomous Kurdish Region to go its own way, meaning become independent of the Central Government of Iraq, as a sovereign nation.
While that is a positive development amid the otherwise deteriorating situation in Iraq, it could also upset those Iranian individuals, and companies, who prefer that their large accounts in Kurdish banks not be required, by newly-appointed regulators or compliance officers, to be identified as Iranian, or to prove legitimate Source of Funds, or the identities of Beneficial Owners. While the present autonomy of the region has fostered a total lack of AML/CFT and sanctions compliance regarding Iran, this could rapidly change with independence. Money launderers prefer to move endangered funds long before they are at risk.
Therefore, should your compliance staff notice any large transfers, coming from financial institutions in the KRG, or originating from there, and passing through one or more intermediary banks, you might want to institute enhanced due diligence procedures, on the funds, the remitter, and the recipient. The last thing you want in 2014 is to be nailed for Iran sanctions evasion activity, and Iranian commerce with the KRG, and the fact that Iranian funds transfer into and through Erbil, into your bank, is a real possibility.