Among the myriad threats to the Joint Comprehensive Plan of Action, front and center is the inability of just about anyone to convince the world’s largest banks to facilitate transactions between Iran and foreign companies. The banks’ coyness toward Iran has caused increasingly loud grumbling in Tehran and a creeping sense of unease in Western capitals. Banks have reason to be wary, not least because of the very political issues of continued unilateral US sanctions and the uncertainty surrounding the upcoming US presidential elections.

Yet, beyond the unpredictable and increasingly politicized issues surrounding the agreement, an opportunity for positive change lies in getting Iran removed from the very short list of countries deemed high risk and noncooperative by the international Financial Action Task Force (FATF). Iran was put on the blacklist because it was determined that the country lacked the means or the will — depending on who is asked — to combat money-laundering and terrorist financing. Taking major steps to get Iran off this list would ease some of the banks’ concerns, help facilitate the legal trade envisioned under the nuclear deal and aid in strengthening the global anti-money laundering (AML) regime — a decidedly nonpolitical and uncontroversial goal.

For almost a decade, Iran’s financial system was seen as an effective target for sanctions architects determined to cut the country off from international trade. Sanctions sparked the proliferation of unregulated financial institutions adept at sanctions busting that — along with more established banks — found surreptitious and novel ways to move cash around the world.

Media began to report on suitcases filled with dollars flowing through Tehran’s Imam Khomeini International Airport and suspicious truckloads of Iranian gold being seized in Turkey. A barter system was created with willing international partners, and Iran began to make extensive use of a motley but effective network of middlemen and front companies to facilitate transactions. Under such a secretive system designed specifically for survival, corruption expanded exponentially and a culture of circumvention of basic financial legal standards took root.