A joint investigation by Der Spiegel and ARD’s Report Mainz reveals how companies linked to Iran’s regime allegedly moved €147 million through a German bank and pursued majority ownership of the institution, with a new acquisition attempt now under way.
Iran’s Financial Network Targeted German Bank tEN31
An Iranian regime-linked financial network sought to acquire a German bank in Bavaria as part of efforts to circumvent international sanctions and facilitate the transfer of oil revenues to Iran, according to a joint investigation by German newsmagazine Der Spiegel and ARD’s Report Mainz.
The investigation, titled “A German Bank in Tehran’s Sights,” describes a complex network of hundreds of shell companies allegedly used by the regime to maintain access to financial services despite international restrictions. Investigators uncovered evidence that companies connected to this network attempted to acquire a controlling stake in tEN31, a bank based in Ottobrunn, near Munich.
According to internal documents from Germany’s Federal Financial Supervisory Authority (BaFin) obtained by the journalists, €147 million passed through a single account at tEN31 over a period of ten months beginning in the summer of 2023. A substantial portion of the transactions involved companies linked to Iran’s regime.
The suspicious Iran-related payments reportedly accounted for more than half of the bank’s total balance-sheet volume, raising serious questions about the extent to which the institution had become entangled in the regime’s financial operations.
The investigation also found that the companies involved were pursuing a majority stake in the bank. The apparent objective was to continue Iran-related business that had previously been prohibited at another financial institution.
Documents Point to Bank Shahr’s Role
BaFin documents explicitly identify Bank Shahr, an Iranian bank with established ties to the regime, as the force behind the original acquisition attempt.
According to the supervisory authority’s findings, the individuals and companies involved “planned and executed the acquisition of a majority stake in tEN31 bank on the instructions of (…) Bank Shahr Iran.”
Bank Shahr has been subject to US Treasury sanctions for years. Companies associated with the bank have also been linked to transactions involving illicit oil trading, making its reported involvement in the German bank acquisition particularly significant.
The documents further indicate that, in 2023, a three-person delegation from Bank Shahr planned to visit tEN31’s headquarters in Ottobrunn. The prospect of such a visit reportedly raised concerns among people familiar with the matter, including fears that intelligence services could begin investigating the activities.
Germany’s domestic intelligence authorities eventually took an interest in the case. BaFin intervened, blocked the sale of the bank’s shares and deprived the individuals involved of their voting rights.
However, the investigation by Der Spiegel and Report Mainz indicates that the effort to gain control of tEN31 has not ended.
New Acquisition Attempt Through a Swiss Company
According to the investigation, a new attempt to acquire the German bank is now under way through a small Swiss company based in the canton of Zug.
Documents point to concrete connections between the latest effort and the original acquisition attempt. A notarial document relating to the Swiss company reportedly shows an Iranian-born man alongside its formally registered board members. The same individual appears in records concerning the earlier attempt and had previously acted as a trusted intermediary for Bank Shahr or companies associated with it in other business dealings.
An anti-money-laundering questionnaire also identifies an employee of the man as the beneficial owner of the Swiss company. Several individuals familiar with the documentation reportedly confirmed to the journalists that the first and second attempts to acquire tEN31 are directly connected.
These links raise concerns that the acquisition effort may represent a continuation of the earlier strategy through a different corporate vehicle, following the German regulator’s intervention.
Why Control of a Bank Matters to Tehran
Rebecca Schönenbach, an independent adviser specializing in anti-money laundering and counterterrorism, explained the risks associated with allowing a regime-linked network to gain control of a bank.
“A bank not only enables the deposit and lending of money; it also offers various ways to circulate money and, above all, conceal the Iranian regime’s financial flows. The risks therefore increase considerably,” she said.
The ability to control a banking institution could offer a financial network far greater opportunities than simply maintaining accounts or transferring funds. It could potentially provide access to additional financial channels and make it more difficult for authorities to trace the origins, destinations and beneficiaries of transactions.
Schönenbach has monitored the activities of Iran’s regime in Germany for years. According to the investigation, people who previously worked as intermediaries for Iran described an intricate and opaque network of companies operating across Germany and other European countries.
The network allegedly enables the regime to circumvent sanctions and transfer revenues from oil and petroleum-product sales back to Iran.
Oil Revenues and the Regime’s Sanctions-Evasion Network
Oil exports remain a central source of revenue for Iran’s regime. These funds sustain the regime’s economic and security apparatus, including the Islamic Revolutionary Guard Corps (IRGC), which plays a central role in its domestic repression and regional operations.
International sanctions are designed in part to restrict the regime’s access to financial channels and limit its ability to use oil revenues. A network of shell companies, intermediaries and financial institutions can undermine those restrictions by obscuring the ownership of businesses, the origin of funds and the entities ultimately benefiting from transactions.
The tEN31 case illustrates how these networks can extend beyond Iran’s borders and penetrate European financial infrastructure. The reported flow of €147 million through a single account, the original attempt to acquire a majority stake in the German bank, and the emergence of a second acquisition effort through a Swiss company point to the scale and persistence of the challenge.
The German investigation also raises a broader question for European regulators: whether efforts to prevent sanctions evasion are keeping pace with the corporate structures used to conceal financial connections.
BaFin’s intervention stopped the original share sale, but the reported new attempt demonstrates why continued scrutiny of beneficial ownership, cross-border corporate relationships and transactions involving Iranian regime-linked entities remains essential.
The case places the spotlight on the use of European financial institutions in a wider system designed to preserve Tehran’s access to money despite international sanctions.