Regulatory Alerts2011-05-02
Added
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Reporting Requirements Under Section 104(e)
The Financial Crimes Enforcement Network proposes regulations requiring U.S. banks maintaining correspondent accounts for foreign banks to inquire of and report to FinCEN specific information upon receiving a written request. The reporting obligations cover whether the foreign bank maintains a correspondent account for an Iranian-linked financial institution designated under the International Emergency Economic Powers Act, or has processed transfers of funds within the preceding 90 calendar days related to such an institution or an IRGC-linked person. Banks must submit these reports within 30 days of the request and include details regarding non-responses or inability to verify the absence of such relationships.