Imposition of Fifth Special Measure against the Islamic Republic of Iran as a Jurisdiction of Primary Money Laundering Concern

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.

The latest form for Imposition of Fifth Special Measure against the Islamic Republic of Iran as a Jurisdiction of Primary Money Laundering Concern expires 2026-07-31 and can be found here.