Briefing Summary

The Duality Problem - How Everyday Trade Can Enable Sanctions Evasion in Iran

A washing machine component and a drone guidance system can share the same microchip. A chemical used in perfume production can be repurposed for weapons. The same goods that flow through legitimate global supply chains every day are being systematically exploited by Iranian procurement networks to rebuild military capabilities in the face of intensifying international sanctions. This briefing examines how that happens and what it means for your organisation.

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What's Inside

• An explanation of dual-use goods and why they sit at the heart of Iran's sanctions evasion strategy - covering how Iran's "Axis of Evasion" procurement network spans Asia, Europe, Africa, and the Middle East, using front companies, foreign facilitators, and opaque financial pathways to access restricted technology
• A breakdown of the seven highest-risk Harmonised System (HS) codes associated with Iranian dual-use procurement - including integrated circuits, telecom equipment, CNC machinery, radar systems, and bearings - and how each maps to specific military applications including missile guidance, UAV production, and nuclear centrifuge manufacturing
• An explanation of how Iran's procurement model works in practice - from state-linked entities identifying required components, to third-country intermediaries masking the true end user through false declarations, invoice manipulation, transshipment, and fragmented consignments
• A detailed case study of Ascotec Holding GmbH - a wholly owned subsidiary of Iran's state mining consortium operating from a polished office overlooking the Rhine in Düsseldorf, with annual group turnover of €500 million, and trade data showing shipments of washing machine components routed to Iran via Turkey, a known sanctions circumvention hub
• A case study on Chinese chipmaker SMIC's alleged supply of chipmaking tools and technical training to Iran's military industrial complex, and how a decade-long procurement scheme used Chinese front companies to illicitly acquire US dual-use components for the IRGC and Iran's Ministry of Defence
• A guide to international sanctions guidance from FATF - covering Recommendations 1 and 7, expected controls for financial institutions, and why GCC jurisdictions face particular scrutiny given their role as major trade, logistics, and re-export hubs
• Practical guidance on how AMAN Powered by Themis can help - from AI-powered counterparty screening and real-time adverse event monitoring to deep-dive trade data investigations identifying suspect HS codes and end-user agreements

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