American Bid to Put Pakistan on FATF Watch-List Fails in Paris

[Riaz Haq]

Financial Action Task Force (FATF), the financial watchdog group for terror financing, has delayed any decision to put Pakistan on its watch list, according to its spokesperson Alexandra Wijmenga-Daniel.  This move was sponsored by the United States and its European allies.

The FATF statement released after the meeting that ended on February 23, 2018 identified the following nations as being on its watch list: Ethiopia, Iraq, Serbia, Sri Lanka, Syria, Trinidad and Tobago, Tunisia, Vanuatu and Yemen.

FATF Decision Delayed: 

It appears that the American bid failed at this month's FATF meeting. Pakistan's Chinese allies and Muslim friends among the Gulf Arabs and Turkey prevailed at the February 18-23 meeting in Paris, France. If US persists and Pakistan is placed on the FATF "grey list" at the June meeting, how will it impact Pakistan economy and the geopolitics of the region? Will it be good or bad for American interests in Afghanistan and Pakistan? Will it help or hurt China?

Effect on Pakistan:

Pakistan's economy will be hurt if it goes on the FATF watch-list.  It could increase support for radicals and strengthen the hands of anti-American extremists.

Being on the list will draw more scrutiny for all banking transactions involving Pakistani entities. This additional scrutiny may drive away some businesses and investors and hurt Pakistan's economy.

Risk-averse international banks, some of whom have already faced heavy fines by US regulators for transactions elsewhere, may decide to shy away from working with Pakistani banks. This will hurt Pakistan's international trade and worsen its current account deficits. It will increase the likelihood of debt default.

China, currently the biggest foreign investor in Pakistan, will continue to invest in the country. FATF decisions will have little impact on the execution of China-Pakistan Economic Corridor (CPEC).

Impact on the United States:

There's a history of the US ratcheting up pressure on Pakistan to do its bidding. The Obama administration in years 2012-15 helped put Pakistan on the FATF watch-list. President Obama also exerted other forms of pressure on Pakistan without results. Obama's tactics ended up further alienating Pakistanis and made Pakistan less cooperative with the United States. In 2011, Pakistan cut off US-NATO supply land routes through its territory to Afghanistan.

If history repeats itself and Pakistan does go back on the FATF watch-list under US pressure, the outcome this time is not likely to be any different than it was the last time. It will serve to further alienate Pakistan, and it will strengthen the hands of the hardliners.  It will make any resolution of the difficult Afghan problem even more difficult.

China's Interests:

China will likely be the biggest beneficiary of the US effort to put Pakistan on the FATF watch list. The Chinese will have the biggest slice of Pakistan's rapidly growing middle class consumer market. Chinese investors, traders and businessmen will have little competition from the West in the world's sixth most populous nation. Geopolitically, the US influence will dramatically diminish in the region. America's hopes of a favorable outcome in Afghanistan will not materialize.

Summary:

American bid to put Pakistan on FATF terror financing watch-list failed in Paris. However, the Trump Administration's continuing efforts to do so may succeed at the June meeting.  If that were to happen, it will turn out to be pyrrhic victory. Pakistan will be hurt in the short term but the US policy of all sticks and no carrots will prove to be counterproductive in the long run. Washington will lose whatever little political capital and influence it still has left in Pakistan.  America's Afghan problem will become even more intractable without Pakistan's help. China will be the biggest beneficiary of America's folly.

Related Link:

Haq's Musings

Will Pakistan Yield to Trump's Pressure?

Checkered History of Pakistan-Afghan Ties

Pakistan Rising or Falling? Reality vs Perception

Steve Coll's Directorate S

CPEC Myths and Facts

CPEC Transforming Least Developed Regions of Pakistan

Pakistan-China-Russia vs India-Japan-US

Riaz Haq's Youtube Channel

PakAlumni Social Network

[Riaz Haq]

View from #India: "#FATF has failed to nail #Pakistan" https://www.dailyo.in/politics/fatf-terrorism-diplomacy-pakistan-ch... … via @dailyo_

https://www.dailyo.in/politics/fatf-terrorism-diplomacy-pakistan-ch...

It was widely speculated that with US, France, Britain and Germany supporting such a move, Pakistan would not escape inclusion. Until the end there was confusion because of mixed signals emanating from FATF deliberations. Pakistan has apparently been given three months more for taking steps as set out by the FATF to clean up its system.

Pakistan was on FATF’s grey list from 2012 to 2015. Why it was felt in 2015 that Pakistan had done enough to fulfil FATF’s criteria to justify removal is unclear when in actual fact Islamabad has even thereafter continued to use terrorism to achieve its political objectives in India and Afghanistan.

[Riaz Haq]

China expresses support for Pakistan’s anti-terrorism efforts
Source:Xinhua Published: 2018/2/27 22:43:39

http://www.globaltimes.cn/content/1091020.shtml


China on Tuesday expressed support for Pakistan's fight against terrorism, urging the international community to view the country's anti-terrorism efforts in an objective and impartial way.

The government and people of Pakistan have contributed and sacrificed a lot in their fight against terrorism and made great efforts in ground operations as well as combating terrorism in the financial sector, said Foreign Ministry spokesperson Lu Kang at a routine press conference.

He called on the international community not to criticize Pakistan with prejudice.

Lu's comments came after some countries persuaded members of the Financial Action Task Force last week to place Pakistan on the "grey list" of nations with inadequate efforts to control terror financing.

China, as an all-weather strategic cooperation partner of Pakistan, will continue to strengthen communication and coordination with Pakistan in anti-terrorism cooperation, Lu said. 

[Riaz Haq]

Pakistan can achieve economic revival as transshipment hub for trade with China
By Hu Weijia Source:Global Times Published: 2018/2/27 22:18:40

http://www.globaltimes.cn/content/1091010.shtml


Pakistan's economic woes have worsened five months before national polls, according to a report by Bloomberg. China will likely be willing to offer more assistance to help its neighbor improve economic conditions, but the question is how to find an effective way.

Pakistan's trade deficits are hitting records while its foreign exchange reserves continue to fall, Bloomberg reported. Pakistan's economy is facing chronic problems for many reasons, but the fact that Pakistan's GDP grew 5.3 percent in fiscal 2017 - the fastest pace in a decade - can't be ignored. 

The two countries will move ahead with the China-Pakistan Economic Corridor (CPEC), which has become a driving force for Pakistan's economic growth. The question is how its investment-driven growth can be transformed into internal momentum for economic expansion.

While the first phase of the CPEC concentrated on infrastructure projects, the second part should focus on setting up special economic zones and establishing mutual connectivity to support economic integration. 

Pakistan's strategic location is a major attraction for companies to invest in and obtain lucrative returns. Now, the nation must give full play to its advantages. 

The most important maritime trade route that China has now is through the South China Sea and the Strait of Malacca. The CPEC is designed to connect Gwadar Port in Southwest Pakistan with China's inland areas, offering another route for Chinese importers and exporters. 

Improvements in Pakistan's trade-related sectors, such as warehousing, logistics, integrated services and e-commerce, can turn the nation into a new transshipment point for exports to China. Efforts to upgrade the bilateral free trade agreement will also help realize economic potential.

Trade and financial deficits have long been seen by some observers as the thorniest issues faced by the South Asian country. Making Pakistan a new transshipment point will help the nation boost exports and slash its trade deficit with China. This situation may also help Pakistan conserve its foreign exchange reserves.

China is expected to continue to encourage outbound investment, but investors should also be reminded to exercise caution. The CPEC is one of the flagship projects in China's Belt and Road initiative. The Chinese government should give more guidance to companies with an eye to the South Asian country to reduce the risk of inefficient investment.

[Riaz Haq]

Trump’s diplomacy is all about the ultimatum. That could spell disaster.

Jackson Diehl Deputy Editorial Page Editor

https://www.washingtonpost.com/opinions/global-opinions/trumps-dipl...

President Trump’s supporters expected he would bring a new, business-seasoned negotiating style to U.S. diplomacy. What we’ve seen in the past month is something rather different: the art of the ultimatum.

Sure, Trump’s team has been bargaining with Mexico and Canada over trade, with China over North Korea, and with Russia over Syria and Ukraine. But the most striking thing about the president’s diplomacy so far in 2018 has been the public demands he has placed on European allies, Pakistan and the Palestinians. He has told the Europeans, and Congress, that he will withdraw from the nuclear deal with Iran unless they agree to a “new supplemental agreement” by the middle of May. He pledged to cut off aid to the Palestinians unless they agree to participate in the peace talks he wants to sponsor. And he has already frozen aid to Pakistan for giving “safe haven to the terrorists we hunt in Afghanistan.”

Perhaps, for Trump, this is simply another way to bargain. If so, the fallout from the president’s would-be diktats suggests it’s not working.

Take Pakistan. Trump’s first tweet of the year blindsided Islamabad with this broadside: “The United States has foolishly given Pakistan more than 33 billion dollars in aid over the past 15 years, and they have given us nothing but lies & deceit.” Days later the administration announced it was suspending nearly all security aid, up to $1.3 billion annually, while saying it could be restored if Pakistan took steps against the Taliban and other terrorists. In other words: Meet U.S. demands or forfeit the funds.

Pakistani officials predictably rejected the public challenge, saying they didn’t need the money and anyway could probably get it from China. Then they shut down the Pakistan operations of Radio Free Europe, which broadcasts in the Pashto language used on both sides of the border between Pakistan and Afghanistan, saying it served a “hostile intelligence agency’s agenda.”

Then, on Jan. 20, came a deadly assault on the Intercontinental Hotel in Kabul, which killed at least 22, including several Americans, and bore all the hallmarks of the Haqqani network, the Taliban faction that Pakistan’s military intelligence agency is accused of supporting, if not directing. If Trump’s tweet was meant to intimidate, it appears to have spectacularly backfired.

Next come the Palestinians, who predictably took umbrage when Trump recognized Jerusalem as the capital of Israel. Palestinian Authority leaders refused to meet with Vice President Pence when he visited the region and said they would not consider the peace plan the White House has been working on. That prompted Trump to announce that aid to the Palestinians would be cut off “unless they sit down and negotiate peace.” Half the $125 million in expected U.S. aid to the U.N. refu­gee agency for Palestinians has already been withheld.

To punish Trump for that ultimatum, the Palestinians need only sit tight. The withdrawal of U.S. aid is the last thing Israel wants — it would cause the collapse of the West Bank Palestinian security forces that in recent years have worked closely with Israel to prevent terrorist attacks. Israeli military forces might have to redeploy in Palestinian areas they now avoid. In short, if Trump follows through, he’ll do less damage to the Palestinians than to Israel, the ally he thinks he’s appeasing.

[Riaz Haq]

Trump’s diplomacy is all about the ultimatum. That could spell disaster.

Jackson Diehl Deputy Editorial Page Editor

https://www.washingtonpost.com/opinions/global-opinions/trumps-diplomacy-is-all-about-the-ultimatum-that-could-spell-disaster/2018/02/04/a664566e-0776-11e8-8777-2a059f168dd2_story.html?utm_term=.3710e7cb0bef

The most costly Trump diktat, however, concerns the Iran nuclear deal. In a statement stuffed with bullying rhetoric, Trump demanded on Jan. 12 that Europeans and Congress agree within 120 days to a rewrite of the 2015 accord that would impose new conditions on Iran and reverse sunset provisions — without bothering to negotiate with Tehran. European diplomats and a handful of senatorsare duly seeking to finesse something that would appear to address Trump’s demands without actually infringing on the pact — a nearly impossible task.

If they fail, which is likely, Trump will have the choice of failing to deliver on his threat or reimposing U.S. sanctions on Iran. The latter would trigger an international crisis for which the United States would be universally blamed and open the way for Iran to resume the large-scale production of enriched uranium — something it is now prevented from doing.

All these disruptions might make sense if Trump had a plan for what happens after he blows up the status quo. Does he have a strategy up his sleeve for coercing Pakistan? Does he know how the West Bank will be secured if the Palestinian Authority collapses? Does he have a new way to stop Iran from building a nuclear weapon?

He doesn’t. The worst thing about Trump’s ultimatums is that there is nothing behind them. In foreign policy, that’s an invitation to disaster.

[Riaz Haq]

Limits of diplomacy

http://www.unc.edu/depts/diplomat/item/2011/0104/oped/op_byers.html

Appearing in the wake of the recent 30th anniversary of the Iranian hostage release and the momentous events now taking place in Egypt and in other parts of the Arab world, the author claims to see a better way to conduct our diplomacy in the 21st century.–Ed.

Congress and Foreign Affairs
It seems superfluous to ask whether there are limits to what diplomacy can achieve. Yet in light of recent history it is worthwhile to ask this and related questions. It might be better to ask how we can reform traditional diplomacy to meet today’s challenges. Can U.S. diplomacy reach into the deepest cultural recesses of other societies and influence the popular imagination in positive ways? Should this be a goal of diplomacy? Let us look at a few examples.

On January 20, 1981 fifty-two American diplomats were released from captivity in Iran at the very moment that President Ronald Reagan recited the Oath of Office during his Inauguration in Washington, DC. They had been seized by Iranian revolutionaries on November 4, 1979 and held hostage for 444 days with the approval and collusion of the newly ascendant regime under the leadership of Ayatollah Ruhollah Khomeini in violation of international diplomatic agreements and protocols. Khomeini had long been an enemy of Iran’s Shah and of the United States.

On January 27, 1981 President Ronald Reagan welcomed the American diplomats in a ceremony at the White House that I attended. I had served as a diplomat in Tehran from early 1972 to mid 1974 after having studied Farsi at the Foreign Service Institute. During my years in Iran I had traveled widely, lived with an Iranian family, attended many different cultural events, and met students at several universities in Tehran, Isfahan, and Shiraz. I had come to know the people in Iran as culturally and ethnically diverse. And yet all of them lived under the autocratic rule of the Shah and his small group of advisors and military and police generals. And most knew the Shah was our ally.

The seizure of American diplomats in Iran hit Americans like a sudden tornado sweeping across the prairie. Few of us knew where Iran was or what our diplomats were doing there. Yet, television news reports showing them being led blindfolded from the U.S. embassy under armed guards sent a shockwave through the public consciousness. How could this be happening to our diplomats? How could the United States have allowed a group of student revolutionaries to enter the diplomatic compound and assault our embassy and its diplomats? Where were the Marines? All kinds of questions flowed through the news media during the days and weeks after the seizure of our diplomats. President Jimmy Carter and his advisors had few definitive answers. They expressed hope that a misunderstanding had occurred and that our diplomats would soon be released. They continued to work towards this goal for months without success and then on until the final moments of his time in office.

It soon became obvious that the U.S. government had misjudged Iranian sentiments regarding its actions towards revolutionary Iran and in support of the deposed Shah of Iran. Why? What had we missed? There had been warnings from our embassy in Tehran earlier in the year that if the Shah were allowed into the United States for any reason, popular emotions in Iran could explode. These warnings were weighed in White House circles and found to be less worrisome than the need to extend humanitarian help to an ailing Iranian ruler.1

In the Sunday, January 23, 2011 edition of the Washington Post’s Outlook section former ABC-TV “Nightline” chief Ted Koppel wrote a comment about the hostage crisis in which he opined that the Iranian revolutionaries learned how to manipulate U.S. journalists and TV media and, through them, exert pressure on American public opinion and against the Carter administration. Koppel was able to build much of his reputation on his nightly reporting about the hostage crisis.

[Riaz Haq]

Hopes Are Still High In Pakistan Equities
Mar. 9.18 | About: Global X (PAK)
Bader Al Hussain 
Bader Al Hussain
Growth, long-term horizon, research analyst, long/short equity

https://seekingalpha.com/article/4155243-hopes-still-high-pakistan-...

Summary
FATF decision related to Pakistan has only increased monitoring of international transactions.

Only concern is regarding the structural problem of negative balance of payments.

Investor having a long perspective must consider this ETF.

There has been apprehension among foreign investors regarding the impact of FATF (Financial Action Task Force) decision on Pakistan equity market. Since Pakistan's inclusion in the grey list, one can observe such sentiments in the range bound activity of the market.

This aspect was also highlighted by IMF. IMF, in its recent report, has also recommended to strengthen the anti-money laundering and counterterrorism financing regimes.

The decision of FATF to include Pakistan stems from the inability of the country to act against the proscribed organisations that are designated as terrorist by the UN. However, given the public's resentment over government's laxity towards such organisation, it is just a matter of time before effective action is taken.

Further, it is to be noted that Pakistan was included in FATF's grey list during 2012 and 2015. The country was removed after it passed anti-money laundering act. In my view, given the seriousness of the measures that are underway, Pakistan would be able to satisfy the reservations conveyed by FATF within three months.

The macroeconomic impetuses to the PAK still remain, and the reasons are:

Valuations are intact.
CPEC is on the track as early harvest projects have started to come online.
IMF has maintained the forecast of the GDP growth for the next year at 5.6%, which is the highest in the decade.
Foreign investment is on the rise, especially in automobile sector. The details of FDI are shown below.
Senate elections were conducted with the usual hue and cry.
The political landscape is calm and smooth transition is expected.
Inflation is curbed at the average level of 4%.

[Riaz Haq]

#Pakistan may raise $2.5 billion as in new #bond sale to boost #dollar reserves https://www.bloomberg.com/news/articles/2018-03-13/pakistan-may-rai... … via @business

By 
March 13, 2018, 6:22 AM PDT Updated on March 13, 2018, 9:05 PM PDT
Junior finance minister says Islamabad studying all options
Pakistan’s foreign reserves have dwindled in past year
Pakistan’s Minister of State for Finance Rana Afzal Khan said the government may raise the “same” amount of funds from global debt markets as it did at a $2.5 billion sale in November.

A final decision hasn’t been taken yet and the government is studying all options, Khan said in an interview on the sidelines of a conference in the capital, Islamabad, on Tuesday. Pakistan aims to issue bonds or Islamic-compliant sukuk before elections in July as it looks to boost dwindling foreign-exchange reserves and continues to invest in infrastructure projects, Khan told Bloomberg last month in Karachi.

Pakistan last issued dollar debt four months ago shore up its deteriorating finances. The country has been hit by political instability in the past year and its economy is showing increasing signs of vulnerability. Pakistan’s current account and trade deficits have widened as exports lag regional peers, while foreign-exchange reserves have dropped 27 percent to $12.3 billion in the past year.

“It will help cool off immediate pressure, more than a billion dollars a month is being depleted in reserves,’’ said Shahid Ali Habib, chief executive officer at Karachi-based brokerage Arif Habib Ltd. “It would have been better to raise a larger amount last time.”

The World Bank estimated in October that $17 billion of external financing -- or 5 percent to 6 percent of gross domestic product -- is needed in the current financial year through June for Pakistan to bridge its debt payments and current account deficit. Some analysts also believe the nation may need another International Monetary Fund bailout, which would be its 13th since 1988.

The IMF said last week said Pakistan faces continual “erosion” and its widening external and fiscal imbalances mean that “risks to Pakistan’s medium-term capacity to repay the fund have increased” since completion of a three-year $6.6 billion bailout program that ended in Sept. 2016. Pakistan’s current-account deficit could reach 4.8 percent of GDP in the year ending June, according to the IMF.

Miftah Ismail, Pakistan’s de-facto finance minister, said in an interview last week that Islamabad isn’t considering going back to the IMF, but is considering issuing Chinese currency bonds. The ruling party, whose leaders face multiple legal and corruption charges, will be loath to go back to the IMF so soon after the last program ended as it would indicate economic mismanagement.

Investors have also been cautious on Pakistan after the Supreme Court in July barred former Prime Minister Nawaz Sharif from office following a probe into his family finances. Pakistan’s benchmark stock index was the worst performer globally last year, though it has seen a measured rebound since.

[Riaz Haq]

Times of India report: 

https://timesofindia.indiatimes.com/world/pakistan/new-us-national-...

Bolton - a former US ambassador to the UN - believes that Pakistan, a nuclear weapons state, is perpetually teetering on the brink of embracing Islamic extremism and terror. And pushing it too hard could well lead to it becoming "a terrorist country with nuclear weapons", or as Bolton described it last August to Breitbart.com, "Iran or North Korea on steroids".

"...it's clear the President wants to pressure Pakistan more. Well, I agree with that, and I think Obama didn't pressure them enough... But there's a real problem with simply saying, 'By God, we're going to squeeze Pakistan until they finally push the Taliban, the Haqqani network, Gulbuddin Hekmati out of the privileged sanctuaries they've had in Pakistan, push them back into Afghanistan, and stop supplying them, stop giving them weapons, stop giving them money' ", said Bolton to Breitbart.
Bolton said the problem with such an approach is that it might lead to a situation where anti-US sentiment fuels popular support for Islamist radicals and the Taliban.
"If you push too hard, this government in Pakistan is fragile. It has been since the partition of British India ...The military in Pakistan itself is at risk, increasingly, of being infiltrated through the officer ranks by radical Islamists. Many people believe the intelligence services unit already is heavily dominated by Islamists," he explained.
If radicals take over the Pakistan government completely, it's "the ultimate risk" said Bolton.
"...if Pakistani Taliban or other radicals took control of that country, it wouldn't just be another base to launch terrorist operations against us or Western Europe. It would be a terrorist country with nuclear weapons, so it would be Iran or North Korea on steroids right now," he warned.
Too much pressure on Pakistan could backfire, Bolton wrote last August in The Wall Street Journal.
"Putting too much pressure on Pakistan risks further destabilizing the already volatile country, tipping it into the hands of domestic radical Islamicists, who grow stronger by the day. In this unstable environment, blunt pressure by the U.S.—and, by inference, India — could backfire," said the the now NSA in a column for the Journal.
Here's where China can step in and should be pressured to, the new NSA said.
"China's influence is, in some ways, greater than ours" in Pakistan because "there wouldn't be a Pakistani nuclear weapons program without China."
China is the key to keeping the house of cards from collapsing in Pakistan, Bolton said in his Journal column from August.
"If American pressure were enough to compel Pakistan to act decisively against the terrorists within its borders, that would have happened long ago. What President Trump needs is a China component to his nascent South Asia policy, holding Beijing accountable for the misdeeds that helped create the current strategic danger," wrote Bolton.

[Riaz Haq]

New Jurisdiction subject to monitoring
FATF has identified Pakistan as a jurisdiction with strategic AML/CFT deficiencies. The country has developed an action plan with the FATF to address the most serious deficiencies. The FATF welcomed the high level political commitment of Pakistan to their action plan.

http://www.fatf-gafi.org/publications/fatfgeneral/documents/outcome...

Monitoring Iran’s actions to address deficiencies in its AML/CFT measures
In June 2016, the FATF welcomed Iran’s high-level political commitment to address its strategic AML/CFT deficiencies, and its decision to seek technical assistance in the implementation of the Action Plan. Given that Iran provided that political commitment and the relevant steps it has taken, the FATF decided in February 2018 to continue the suspension of counter-measures.

Since November 2017, Iran has established a cash declaration regime and introduced draft amendments to its AML and CFT laws. However, Iran’s action plan has expired with a majority of the action items remaining incomplete. Iran should fully address its remaining action items, including by: (1) adequately criminalising terrorist financing, including by removing the exemption for designated groups “attempting to end foreign occupation, colonialism and racism”; (2) identifying and freezing terrorist assets in line with the relevant United Nations Security Council resolutions; (3) ensuring an adequate and enforceable customer due diligence regime; (4) ensuring the full independence of the Financial Intelligence Unit and requiring the submission of STRs for attempted transactions; (5) demonstrating how authorities are identifying and sanctioning unlicensed money/value transfer service providers; (6) ratifying and implementing the Palermo and TF Conventions and clarifying the capability to provide mutual legal assistance; (7) ensuring that financial institutions verify that wire transfers contain complete originator and beneficiary information; (8) establishing a broader range of penalties for violations of the ML offense; and (9) ensuring adequate legislation and procedures to provide for confiscation of property of corresponding value.

The FATF is disappointed with Iran’s failure to implement its action plan to address its significant AML/CFT deficiencies. Given the Iranian government’s continued efforts to finalize and pass amendments to its AML and CFT laws, the FATF decided at its meeting this week to continue the suspension of counter-measures. The FATF urgently expects Iran to proceed swiftly in the reform path to ensure that it addresses all of the remaining items in its Action Plan by completing and implementing the necessary AML/CFT reforms, in particular enacting the necessary legislation. We expect Iran to enact amendments to its AML and CFT laws and ratify the Palermo and TF Conventions in full compliance with the FATF Standards by October 2018, otherwise, the FATF will decide upon appropriate and necessary actions at that time.

Iran will remain on the FATF Public Statement until the full Action Plan has been completed. Until Iran implements the measures required to address the deficiencies identified in the Action Plan, the FATF will remain concerned with the terrorist financing risk emanating from Iran and the threat this poses to the international financial system. The FATF, therefore, calls on its members and urges all jurisdictions to continue to advise their financial institutions to apply enhanced due diligence to business relationships and transactions with natural and legal persons from Iran, consistent with FATF Recommendation 19.