DIA has issued a reminder to reporting entities about Iran sanctions, following the reimposition of New Zealand’s Iran sanctions regime in late 2025, and the message is clear: stay alert to signs of possible sanctions evasion. The release also reminds reporting entities to consider submitting a Suspicious Activity Report where activity or a transaction is suspected to be connected to sanctions circumvention or evasion.
Why this matters
DIA is warning that a link to Iran may not always be easy to spot. It could be hidden behind another country, another business, or a more complicated transaction. For reporting entities, that means paying close attention when an overseas customer, transaction, or ownership structure does not quite stack up.
What reporting entities should take from this
This does not mean every overseas link is a sanctions issue. It means reporting entities should be alert to less obvious connections and check that their current processes are strong enough to identify and escalate them.
This is a good prompt to review whether your business is:
- Looking beyond basic name or country screening.
- Collecting enough information to understand who is really behind a customer or transaction.
- Escalating unusual cross-border activity appropriately.
- Clear on when a SAR may need to be considered.
Now is a good time to review your processes
DIA’s reminder is a timely prompt for reporting entities to check whether existing controls are fit for purpose. If your business deals with overseas customers, transactions, or structures, this is a good time to review your screening, escalation, and SAR processes and make sure your team knows what to look for.
If you would like help reviewing your current approach or thinking through what this means for your business, get in touch with us.