FinCEN proposes finding five UAE branches of Banque Misr to be of primary money laundering concern — a special measure barring U.S. correspondent accounts, comments due October 1, 2026 — Federal Register (September 2026)

1Sanctions in the shape of a closed account

One of the sharpest instruments in financial regulation is not freezing assets but cutting off the path to dollar clearing. Section 311 of the USA PATRIOT Act gives the Secretary of the Treasury authority to find a foreign financial institution to be of primary money laundering concern and then impose one of five special measures.

What FinCEN has proposed here is among the heaviest of them: prohibiting the opening or maintenance of correspondent accounts — the settlement accounts a foreign bank holds at a U.S. bank — outright. The finding targets the five United Arab Emirates branches of the Egyptian bank Banque Misr.

2The three measures proposed

1. 1Direct cutoffProhibit U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Banque Misr UAE
2. 2Indirect cutoffRequire U.S. financial institutions to take reasonable steps not to process a transaction for the U.S. correspondent account of a foreign banking institution where the transaction involves Banque Misr UAE
3. 3Ongoing dutyRequire special due diligence on foreign correspondent accounts, reasonably designed to guard against their use to process transactions involving Banque Misr UAE

The three are layered because closing direct accounts alone can be routed around. The second reaches transactions passing through other foreign banks; the third requires the continuing checks needed to find them. The design looks past accounts connected directly to the U.S. financial system to the chain beyond.

3What the proposal states as fact

According to the proposal, Banque Misr UAE has approximately $6 billion in assets and three direct U.S. correspondent relationships through which it accesses the U.S. financial system. FinCEN states that it does not have fulsome insight into the scope of the bank's legitimate activities and, for purposes of this action, assumes that a portion of them are legitimate.

It then states that it has identified at least $1.8 billion in potential Iranian shadow banking activity through Banque Misr UAE since 2024, and assesses that any legitimate activities do not outweigh the risks posed by that facilitation. This is a proposal, not a settled finding.

4The proposed-rule stage

The document is published as a notice of proposed rulemaking, with comments due October 1, 2026 under docket FINCEN-2026-0232. Of the 6,830 Federal Register documents this site holds as of 2026-09-02, 460 are proposed rules, fewer than the 920 rules and far fewer than the 5,384 notices. At the proposed stage nothing is settled and the content can change in light of comments received.

With section 311 measures, however, the publication of a proposal itself functions as a clear signal to the market.