FINCEN has issued an advisory "on the Iranian Regime's Illicit and Malign Activities and Attempts to Exploit the Financial System." The 19-page advisory, issued on October 11, which is intended to help financial institutions "better detect potentially illicit transactions related to the Islamic Republic of Iran," anticipates the full re-imposition on November 5 of sanctions lifted under the nuclear deal with Iran. The US has withdrawn from that multilateral agreement, known as the Joint Comprehensive Plan of Action (JCPOA). "The advisory provides information on the threats the Iranian regime poses to the US financial system as well as to institutions that have correspondent banking relationships with US financial institutions, describes deceptive financial strategies that the Iranian regime uses to evade sanctions, and provides red flag indicators related to specific malign activities and typologies," according to FINCEN's press release. It also seeks to "help foreign financial institutions better understand the obligations of their US correspondents, to avoid exposure to US sanctions, and to address the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) risks that Iranian activity poses to the international financial system." Once the sanctions regime kicks in, FINCEN expects renewed efforts by Iranian officials, financial institutions, front and shell companies, shipping firms and other Iranian entities to evade sanctions to secure hard currency and access to the international finance system. The advisory spells out some of the means by which Iran and its agents seek to evade the sanctions regime to fund the activities of the Islamic Revolutionary Guard Corps and its proxy group, Lebanese Hizballah. Financial institutions are advised to exercise due diligence with exchange houses that may have Iranian connections. Sigal Mandelker, Under Secretary of the Treasury for Terrorism and Financial Intelligence, said that "financial institutions should continue to sophisticate their compliance programs to keep these actors from exploiting them."