FinCEN proposes special measure to block U.S. correspondent accounts for Banque Misr UAE

FinCEN issued a notice of proposed rulemaking, RIN 1506-AB76, under section 311 of the USA PATRIOT Act, finding the five United Arab Emirates-based branches of Banque Misr to be of primary money-laundering concern. The proposal would impose special measure five, which authorizes the Secretary of the Treasury to prohibit, or impose conditions upon, the opening or maintaining in the United States of a correspondent or payable-through account for or on behalf of a foreign banking institution.

The proposed special measure would (i) prohibit U.S. financial institutions from opening or maintaining a correspondent account for Banque Misr UAE; (ii) require U.S. financial institutions to take reasonable steps not to process a transaction for such a correspondent account in the United States if the transaction involves Banque Misr UAE; and (iii) require special due-diligence procedures for foreign correspondent accounts that could be used to process transactions involving Banque Misr UAE.

FinCEN's assessment, based on public and non-public information, states that Banque Misr UAE serves as a critical access node to the U.S. dollar for Iranian illicit finance, posing a risk to U.S. national security and the integrity of the U.S. financial system. Banque Misr UAE consists of five UAE-based branches of the state-owned Egyptian commercial bank, wholly owned by the government of Egypt.

Comments on the notice must be submitted on or before Oct. 1, 2026. Submissions may be made through the Federal e-rulemaking portal at regulations.gov or by mail to FinCEN, P.O. Box 39, Vienna, VA 22183, referencing docket number FINCEN-2026-0232. The Secretary is required to consult with the Secretary of State, the Attorney General, and the Chairman of the Board of Governors of the Federal Reserve System before finalizing the finding.

The proposal notes that the Secretary will consider factors such as actions taken by other nations, competitive disadvantage, systemic impact on international payment systems, and effects on U.S. national security and foreign policy before selecting the final special measure.