Regulatory Alerts2011-10-11
Added
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 Reporting Requirements Under Section 104(e)
The Financial Crimes Enforcement Network requires U.S. banks maintaining correspondent accounts for foreign banks to inquire of and report specific information to FinCEN upon receiving a written request. Banks must determine if the foreign bank maintains a correspondent account for an Iranian-linked financial institution designated under the International Emergency Economic Powers Act, or if it has processed transfers of funds for such institutions or IRGC-linked persons within the preceding 90 calendar days. Additionally, banks must request that foreign banks agree to notify them of any new correspondent accounts established for designated Iranian-linked institutions within 365 days and report instances where they do not maintain a correspondent account for a specified foreign bank when explicitly requested.