What a countermeasures call means for money arriving from Iran

Money arriving in Australia from Iran meets three separate sets of rules, and none of them is a general prohibition on personal transfers. Two are addressed to financial institutions and describe what those institutions must do. The third is a sanctions regime, and it does prohibit outright, but what it prohibits is dealing with named people and entities rather than a country. Reading the three as one blanket ban is the common mistake, and it is worth taking them apart.

Key Takeaways

• The Financial Action Task Force (FATF) has required all jurisdictions to apply effective countermeasures to Iran since February 2020, and reiterated the call in its statement of 19 June 2026.
• The same statement asks countries to ensure that flows involving humanitarian assistance, food and health supplies, diplomatic operating costs and personal remittances are appropriately handled on a risk basis.
• AUSTRAC records that Iran and North Korea are the only foreign countries currently prescribed under the Anti-Money Laundering and Counter-Terrorism Financing (Prescribed Foreign Countries) Regulations 2018.
• Enhanced customer due diligence is mandatory where a customer or a person behind them is present in or formed in a jurisdiction for which the FATF has called for it.
• Australia's Iran sanctions framework prohibits making assets available to, or dealing with assets of, designated persons and entities, with penalties of up to ten years in prison.

What the call for action actually calls for

The list Iran is on is titled High-Risk Jurisdictions subject to a Call for Action, which the FATF itself notes is often referred to externally as the black list. For all countries identified as high-risk, the FATF calls on all members and urges all jurisdictions to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply counter-measures to protect the international financial system.

Iran is in the most serious category. The statement traces how it got there. A high-level political commitment in June 2016 to an action plan that expired in January 2018. Next, a call in October 2019 for increased supervisory examination for branches and subsidiaries of financial institutions based in Iran, enhanced or systematic reporting of financial transactions, and increased external audit requirements for financial groups with respect to their Iranian branches and subsidiaries. Then, since February 2020, given Iran's failure to fully address its action plan, a requirement on all jurisdictions to apply effective countermeasures in line with Recommendation 19.

The countermeasures listed are institutional in character:

• refusing the establishment of subsidiaries, branches or representative offices of Iranian financial institutions and virtual asset service providers;
• prohibiting institutions from establishing branches or representative offices in Iran;
• limiting business relationships or financial transactions with the country or persons in it, on a risk basis;
• prohibiting new correspondent relationships, and requiring a risk-based review of existing ones.

The last of those is the practical constraint on a transfer. A correspondent relationship is the chain a cross-border payment travels along, and where new ones are prohibited and existing ones under review, the route may not exist for a given pair of banks. That is a different thing from the payment being unlawful.

The sentence about personal remittances

The FATF statement then adds a qualification that is easy to miss. When applying countermeasures, countries should ensure that flows of funds involving humanitarian assistance, food and health supplies, diplomatic operating costs, and personal remittances are appropriately handled on a risk basis, considering the terrorist financing or proliferation financing risks emanating from Iran, in line with international obligations.

Personal remittances are named. The instruction is that they be appropriately handled on a risk basis, and the sentence qualifies that basis in the same breath: the risks to be considered are the terrorist financing and proliferation financing risks the FATF identifies as emanating from Iran. It is a direction about how countermeasures are applied to that category of flow, addressed to countries. It is not an exemption, it does not lower any institution's obligations, and nothing in it entitles a particular payment to be processed.

The statement closes by recording that Iran will remain on the list until the full action plan has been completed.

What Australia layers on top

Australia's financial intelligence agency, the Australian Transaction Reports and Analysis Centre (AUSTRAC), treats FATF status as one of several ways a country becomes high risk. AUSTRAC's guidance lists five: deemed high risk or non-cooperative by the FATF, prescribed foreign countries, subject to sanctions, known tax havens, and known to provide support to terrorist organisations.

Iran is in two of those categories at once. On the second, AUSTRAC states that countries can be declared prescribed foreign countries under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 because they pose high risks, and that Iran and the Democratic People's Republic of Korea are the only foreign countries currently prescribed under the 2018 regulations. It is a list of two.

The obligations that follow are on the reporting entity. AUSTRAC states that under the Act a business must conduct enhanced customer due diligence if any of the following are physically present in, or formed in, a high-risk jurisdiction for which the FATF has called for enhanced due diligence:

• the customer;
• any beneficial owner of the customer;
• any person on whose behalf the customer is receiving the designated service, such as a trust beneficiary;
• any person acting on behalf of the customer.

It adds that a business dealing with a high-risk country is likely to need enhanced procedures, to take the risk into account when monitoring transactions, and to submit suspicious matter reports.

The word receiving in that list is worth pausing on. Enhanced due diligence attaches to the person behind the service as well as the account holder, so an inbound payment can trigger it through someone who does not hold the account.

The sanctions framework is a separate question

Sanctions are administered by a different department. The Department of Foreign Affairs and Trade's Iran sanctions framework records that on 28 August 2025 France, Germany and the United Kingdom triggered the snapback of United Nations Security Council sanctions on the basis that Iran had not complied with its obligations under the Joint Comprehensive Plan of Action. On 28 September 2025 the sanctions eased under resolution 2231 were automatically reimposed. Australia implements those by incorporating them into Australian sanctions law, and imposes autonomous sanctions in addition.

The framework page lists nine categories of prohibition:

• exporting or supplying certain goods;
• importing, purchasing or transporting certain goods;
• certain commercial activities;
• transferring technology or technical assistance;
• providing certain services;
• providing assets to designated persons or entities;
• dealing with the assets of designated persons or entities;
• conducting business with specified entities;
• travel bans on listed persons.

A general prohibition on personal transfers is not among them. The asset provisions are precise: it is prohibited to directly or indirectly make an asset available to, or for the benefit of, a designated person or entity, and prohibited to use or deal with an asset owned or controlled by one, with such assets frozen. Names are published on the Consolidated List, and anyone who becomes aware they hold a designated person's asset must freeze it and notify the Australian Federal Police as soon as possible.

Australian sanction laws apply to activities in Australia and to activities undertaken overseas by Australian citizens and Australian-registered bodies corporate, and contravening a sanctions measure is a serious criminal offence carrying up to ten years in prison and substantial fines.

Reading the three together

The three instruments answer three different questions.

None addresses an ordinary personal transfer directly, and the standard behind the strictest of them asks expressly that personal remittances be handled on a risk basis. What the combination produces is friction: fewer correspondent routes, more identity and source-of-funds enquiry, and a higher likelihood that a payment is examined rather than processed quietly. AUSTRAC's own framing is that reporting entities should use this information to guide their risk assessments, compliance programs and decisions about submitting suspicious matter reports.

Where to look next

• Receiving money from Iran - the live rial to Australian dollar rate page for this corridor.
• What a payment rail is made of - the four layers a payment moves through, and what happens to a country cut out of the messaging layer.
• How international transfers work - the correspondent chain a cross-border payment travels along, which is the part the countermeasures reach.
• Understanding transfer fees - what a longer or less direct route costs.
• AUD to IRR - the convert page for the pair, with the story of the rial and the toman.

Sources

• High-Risk Jurisdictions subject to a Call for Action, 19 June 2026, Financial Action Task Force - the description of the list and the call for enhanced due diligence and, in the most serious cases, countermeasures; the history of Iran's action plan from June 2016; the requirement since February 2020 to apply effective countermeasures in line with Recommendation 19; the four countermeasures listed; and the instruction that flows involving humanitarian assistance, food and health supplies, diplomatic operating costs and personal remittances be appropriately handled on a risk basis.
• High-risk countries, regions and groups, AUSTRAC, updated 22 April 2026 - the five ways a country may be considered high risk; the statement that Iran and the Democratic People's Republic of Korea are the only foreign countries currently prescribed under the Anti-Money Laundering and Counter-Terrorism Financing (Prescribed Foreign Countries) Regulations 2018; the four categories of person that trigger mandatory enhanced customer due diligence; and the expectations on enhanced procedures, transaction monitoring and suspicious matter reports.
• FATF updates on global ML/TF risk, February 2026, AUSTRAC, published 2 March 2026 - reporting entities using this information to guide risk assessments, compliance programs and suspicious-matter-report decisions.
• Iran sanctions framework, Department of Foreign Affairs and Trade - the snapback of 28 August 2025 and the reimposition of 28 September 2025 and the measures involved; Australia implementing the Security Council sanctions and imposing autonomous sanctions in addition; the nine categories of prohibition; the prohibitions on making assets available to and dealing with the assets of designated persons and entities, the Consolidated List and the duty to freeze and notify the Australian Federal Police; and the extraterritorial reach and the penalties of up to ten years in prison.

General information about the international and Australian rules that apply to money arriving from Iran. Not legal advice, not financial advice, and not a recommendation of any product or institution. Sanctions listings change; the Consolidated List is the current record. Reviewed by the Tradergy editorial team, September 2026.