28 Mar 2025

🏦FinCEN's Proposed Renewal on Reporting Obligations for U.S. Banks

Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of Reporting Obligations on Foreign Bank Relationships With Iranian-Linked Financial Institutions Designated Under IEEPA and IRGC-Linked Persons Designated Under IEEPA

Summary

As part of its continuing effort to reduce paperwork and respondent burden, FinCEN invites comments on the proposed renewal, without change, of certain existing information collection requirements found in Bank Secrecy Act (BSA) regulations. Specifically, the regulations require that upon receiving a written request from FinCEN, a bank located within the United States that maintains a correspondent account for a specified foreign bank must ask the foreign bank, and report to FinCEN, about transactions or other financial services provided by that foreign bank to Iranian-linked financial institutions designated under the International Emergency Economic Powers Act (IEEPA) and Islamic Revolutionary Guard Corps (IRGC)-linked persons designated under IEEPA. This request for comments is made pursuant to the Paperwork Reduction Act of 1995.

Agencies

  • Treasury Department
  • Financial Crimes Enforcement Network

Business Impact ?

$$$ - High

The regulation mandates compliance and reporting obligations for U.S. banks regarding foreign bank relationships with Iranian-linked institutions, impacting operational processes and potential financial liabilities. This affects U.S. banks' cost structures and regulatory compliance strategies.

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