The United States and its allies around the world need to coordinate better to uncover Iran’s money laundering schemes.

Iran’s leaders are giving a money-laundering masterclass on using the quirks of geography to jump jurisdictions, evade sanctions, and outwit detection. Iran’s new supreme leader, Mojtaba Khamenei, used these techniques to hide his estimated $3 billion in wealth. At the same time, the Iranian regime leverages the same strategies to move additional billions in illicit oil revenue, used to fund terror and missile attacks across the region.

Criminals love crossing borders. Moving jurisdictions adds layers of opacity and protection. But for governments trying to stop illicit financial flows, national borders are barriers. Foreign laws demand modified approaches, while overseas bureaucracies compound legal hurdles and present opportunities for corruption, obstruction, or delay.

To stop the cash funding strikes on US troops and Gulf allies, the United States must take steps — starting with its own laws — to limit the jurisdictional loopholes that make the cross-border transfer of illicit billions effortless.

When Iran’s supreme leader wanted to launder his stolen billions, he turned to his globetrotting bagman, Ali Ansari. As the front man for an anonymous empire, Ansari’s geographic spiderweb exploits opaque loopholes that add layers of cross-border complexity.

Ansari was born in Iran in 1968 and has a regular presence there, but you wouldn’t know that from his global footprint. Ansari is a citizen of Cyprus (or, if convenient, the tiny Caribbean nation of St. Kitts and Nevis). His legal address is a PO box in Dubai. He is the owner of companies in the Isle of Man and Luxembourg, using these companies to purchase luxury property in England, Spain, and Germany.

Ansari’s first geographic strategy involved establishing citizenship in multiple countries, not by living there, but by purchasing citizenship for a fee. These so-called “golden passports” provide an easy way for bad actors to evade laws and investigations.

America’s adversaries love golden passports. The Taliban’s intelligence chief, Asadullah Khalid, bought a golden passport from Dominica for $100,000. Hossein Shamkhani, a central figure in Operation Economic Fury, also relied on Dominican citizenship to conceal his sanctions-evasion network. Inexplicably, in February, the US Treasury Department withdrew an advisory on St. Kitts’ golden passports despite known risks.

Next, Ansari relies on shell companies—lots of them. Ansari’s Frankfurt Hiltons lead to a tangled web of front companies spanning Germany, the Netherlands, and Luxembourg. At the end of the trail: another anonymous Caribbean shell company.

Shell companies are a favorite tool for Iranian evasion. Iran used UAE shell companies to obtain restricted American technology for military drones—drones currently targeting US forces—while Shamkhani’s operations involved dozens of shell companies moving billions in illicit oil and cash for Iran.

Finally, Ansari relies on the ideal opaque overseas asset: luxury property. Western real estate combines stable value, discreet cash purchasing, and minimal oversight. Unsurprisingly, it’s a favorite destination for the dirty money of dangerous regimes, from Saddam Hussein’s French Riviera villa to the $14 million Austrian ski chalet (purportedly) owned by one of Vladimir Putin’s daughters.

In December 2025, the Treasury issued a rule increasing anti-money-laundering scrutiny of US residential real estate (although a federal court decision has put the rule on hold). If upheld on appeal, the real estate rule will be an important step toward cutting off dirty money. Unfortunately, commercial real estate, like Ansari’s luxury hotels, would still be exempt.

All of these tools—from golden passports to shell companies—harm America’s interests by adding layers of secrecy, complexity, and burden that block efforts to track and seize illicit cash. To stop the money from keeping Iran afloat, Washington must prioritize closing these loopholes now.

The United States should bring pressure against countries issuing golden passports, demanding the immediate revocation of passports to Iranian officials, Islamic Revolutionary Guard Corps  (IRGC) members, and sanctioned Iranians. This is not impossible—Dominica revoked Shamkhani’s passport. But America must also address this national security failure at home, shutting down its own golden passport program.

The United States should crack down on anonymous shell companies, both by pressuring countries with lax corporate registry laws to track the secret owners behind front companies and by addressing its own failings by fully enforcing the Corporate Transparency Act and resisting the dangerous effort to repeal the law.

America needs to push allied countries in Europe, Asia, and the Middle East to develop meaningful regulations that keep dirty money out of their luxury real estate sector while also closing domestic vulnerabilities by extending residential property disclosure requirements to commercial real estate transactions.

To stop the billion-dollar empire of Iran’s leaders, we need to cut off the ability of people like Khamenei, Ansari, and Shamkhani to hide in the shadows. Right now, too many countries, including the United States, are helping them by turning off the light.

About the Author: Josh Birembaum and Susan Soh

Josh Birenbaum is deputy director of the Center on Economic and Financial Power at the Foundation for Defense of Democracies. He is an expert on economic security and illicit finance, with a focus on corruption, anti-money laundering, and countering the financing of terrorism (AML/CFT), economic statecraft, critical supply chains, and economic power competition. Josh has appeared on Fox News, BBC Radio, Times Radio, and CBN; he has been published by The New York Post, Newsweek, National Review, The Hill, The National Interest, The Washington Examiner, Euronews, and The Telegraph.

Susan Soh is a research associate with CEFP. Her research focuses on China’s role in the global economy. Before her time at FDD, she was a Boren Scholar in Taipei, Taiwan. During her undergraduate studies, Susan interned at S&P Global Commodity Insights and an intellectual property consulting firm in Taipei. She holds a BA in international studies and Chinese from the University of Mississippi, with a minor in economics.

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