Imposition of Fifth Special Measure against the Islamic Republic of Iran as a Jurisdiction of Primary Money Laundering Concern
Extension without change of a currently approved collection
No
Regular
03/31/2026
Requested
Previously Approved
36 Months From Approved
07/31/2026
127
15,960
6
15,960
0
0
In November 2019, FinCEN issued a final rule imposing the fifth special measure to prohibit U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Iranian financial institutions. The rule requires that U.S. financial institutions take reasonable steps to avoid processing transactions through the correspondent account of a foreign bank in the United States if such transactions involve an Iranian financial institution, and requires U.S. financial institutions to apply special due diligence that is reasonably designed to guard against the use of correspondent accounts being used to process prohibited transactions involving Iranian financial institutions. See 31 C.F.R. § 1010.661.
U.S. financial institutions are required under 31 C.F.R. § 1010.661(b)(3)(i)(A) to notify their foreign correspondent account holders that they may not provide Iranian financial institutions with access to correspondent accounts maintained at the U.S. financial institution. The requirement is intended to ensure cooperation from correspondent account holders in denying the Islamic Republic of Iran (Iran) access to the U.S. financial system. U.S. financial institutions are required under 31 C.F.R. § 1010.661(b)(4)(i) to document compliance with the notification requirement. The information is used by Federal agencies and certain self-regulatory organizations to verify compliance with 31 C.F.R. § 1010.661.
US Code:
31 USC 5318A
Name of Law: USA PATRIOT Act Pub. L. 107-56
When these OMB control numbers were last renewed in 2023 and 2024, FinCEN estimated that because approximately 15,000 to 16,500 U.S. financial institutions could potentially maintain correspondent accounts for foreign banks, they were all equally likely to incur recordkeeping burdens. In 2025, FinCEN refined its burden assignment methods by distinguishing between all covered financial institutions that could potentially become respondents if they were to maintain a correspondent account for a foreign bank and those that might reasonably be expected to actually be respondents in a given year because they bear indicia of already maintaining such accounts. As a result, in 2025, FinCEN revised the estimated expected number of U.S. financial institutions that maintain a correspondent account for a foreign bank to 127. This is the primary reason for the change in the burden estimate.
In addition, FinCEN revised its burden methodology to account for a staggered decrease in burden in the years following the first year after the publication and implementation of a Section 311 final rule imposing special measure five. Thus, the average time per respondent has been decreased from a uniform burden assignment of one hour in any given year in the prior renewals to 0.05 hours given the number of years elapsed since the first year in which the final rule implemented this imposition of special measure five.
$0
No
No
No
No
No
No
No
FinCEN Resource Center 800 767-2825 frc@fincen.gov
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
03/31/2026
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Imposition of Special Measures Against Iran