This is the case of person A, an Iranian national living in Korea, who was refused a bank account at a Saemaul Geumgo branch. In March 2024, the National Human Rights Commission of Korea (NHRCK) ruled that this refusal was a clear act of discrimination. This case has been written up to help anyone in a similar situation understand the full picture and know what they can do about it.

What happened?

Person A, an Iranian national who had been living in Korea on a marriage migrant (F-6) visa since August 2020, visited a Saemaul Geumgo branch in 2022 to open a bank account in their own name.

Up to that point, A had been sharing their husband’s bank account and debit card. However, having an account in their own name was necessary for receiving official documents from public institutions and managing everyday life.

The teller at the branch refused to open an account. The only reason given was: “because you are an Iranian national.” A’s husband filed a complaint with the NHRCK, arguing this was discrimination based on nationality.

Why did being Iranian become a problem?

FATF and “high-risk countries”

At each of its plenary meetings, FATF publishes a list of countries that do not properly follow international standards. Countries are placed on either a “high-risk” list (the blacklist) or an “increased monitoring” list (the grey list). Iran has been designated a high-risk country since 2011, and as of 2025 it remains on the list of “high-risk jurisdictions subject to a call for action,” alongside North Korea. (Financial Services Commission press release)

There are two main reasons FATF treats Iran as high-risk:

  • Terrorism financing concerns: The international community has raised serious concerns that the Iranian government has provided funding to armed groups such as Hamas and Hezbollah.
  • Non-compliance with international standards: Iran has not implemented FATF’s recommendations or anti-terrorism-financing conventions, which is why it remains on the watchlist and faces significant restrictions in international financial transactions.

How FATF standards flow from the global body down to your local branch

In this case, Saemaul Geumgo cited KoFIU guidelines as the basis for refusing to open an account for an Iranian national. However, KoFIU later stated that it had never instructed financial institutions to refuse accounts as a default rule. Saemaul Geumgo had simply misread the guidelines. The Financial Services Commission

also officially confirmed this in a press briefing in March 2024, stating: “Current regulations do not make it a principle to refuse new account applications from nationals of FATF-designated high-risk countries.”

Comparing the arguments: Saemaul Geumgo vs. the NHRCK

How the guidelines were interpreted

Saemaul Geumgo’s position

  • During the customer identification process, an alert flagged A as a “caution subject.” The branch processed the case in line with what it understood to be a rule requiring refusal of account opening for Iranian nationals.
  • Saemaul Geumgo understood KoFIU guidelines to mean that financial institutions were free to refuse transactions with Iranian customers.

The NHRCK’s finding

  • KoFIU clarified that its guidelines did not instruct refusal, but rather gave financial institutions a choice between two options: either carry out enhanced customer due diligence or refuse the transaction.
  • The confusion arose because the original FATF plenary statement’s phrase “restrict financial transactions” had been mistranslated into Korean as “suspend transactions,” causing unnecessary misunderstanding.

The risk of penalties

Saemaul Geumgo’s position

  • Beginning a transaction with a high-risk customer triggers a range of obligations — reporting, record-keeping, and ongoing monitoring duties. Failing to meet these obligations could lead to penalties, so refusal felt like the only safe option.

The NHRCK’s finding

  • The NHRCK acknowledged that these obligations and the risk of penalties are real.
  • However, KoFIU’s guidelines imposed general obligations on financial institutions — they did not instruct them to refuse accounts outright. Those obligations are something all financial institutions are meant to share.

Concerns about being overwhelmed

Saemaul Geumgo’s position

  • If one branch starts opening accounts for Iranian nationals, people may flock to that branch and the workload could become unmanageable.

The NHRCK’s finding

  • There are only around 2,100 Iranian nationals in Korea.
  • Multiple branches across Korea are already opening accounts for Iranian nationals, so there is no reason to expect customers to all rush to one particular branch.

The NHRCK’s final conclusions

1. This refusal was discrimination

The NHRCK ruled that Saemaul Geumgo’s refusal to open an account for A solely because of their Iranian nationality was a violation of the right to equality — an act of discrimination.

The NHRCK also found that refusing outright, without carrying out even a basic individual assessment (such as checking the person’s creditworthiness or risk level), based solely on nationality, had no reasonable justification.

2. The policy was excessive and disproportionate

According to data from the Ministry of Foreign Affairs and the Ministry of Justice, the main purposes for which Iranian nationals in Korea make financial transactions are small everyday activities: paying utility bills, receiving scholarship payments, and so on. Since Iranian nationals were already subject to enhanced customer due diligence requirements, blocking transactions altogether — for the very same reason — was disproportionate and served the bank’s convenience while ignoring the customer’s situation.

Fix the guidelines

The mistranslated phrase “suspend transactions” should be corrected, and the guidelines should be revised so that, rather than refusing based solely on nationality, financial institutions are required to go through an individual customer assessment before deciding whether to proceed with a transaction.

Share the responsibility across financial institutions

It is true that opening a new account creates compliance obligations and some administrative burden for a financial institution. But that burden should not fall on a single institution or a single branch. All financial institutions should share this responsibility. This is the only way to prevent the load from concentrating unfairly in one place.

Specific details such as figures and deadlines may change depending on circumstances. Before taking any steps, please check the latest information with the Immigration Contact Center (1345) or your local Korea Immigration Service office.