Regulatory Alerts2025-03-28
FinCEN Proposed Renewal of Reporting Obligations on Foreign Bank Relationships With Iranian-Linked Financial Institutions and IRGC-Linked Persons
The Financial Crimes Enforcement Network seeks public comments on the proposed renewal without change of information collection requirements under the Comprehensive Iran Sanctions, Accountability, and Divestment Act. These regulations mandate that U.S. banks maintaining correspondent accounts for specified foreign banks must inquire about and report transactions involving Iranian-linked financial institutions and Islamic Revolutionary Guard Corps-linked persons designated under the International Emergency Economic Powers Act. The agency estimates that approximately 9,384 banks are affected by these reporting obligations, which require detailed data submission within specific deadlines upon receipt of a written request from FinCEN.
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