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Anti-Money Laundering

  
Special Measures

The BSA 31 USC 5318A authorized Treasury to find that a foreign jurisdiction, institution, class of transactions, or type of account is of "primary money laundering concern" and to require domestic financial institutions to take certain "special measures" against the primary money laundering concern.  The first four special measures impose information gathering, reporting, and recordkeeping requirements on those financial institutions dealing, directly or indirectly, with the designated jurisdiction or entity.  Under special measure 5 (31 USC 5318A(b)(5)), a financial institution may be prohibited from opening or maintaining a correspondent account or a payable-through account.

Pursuant to this authority, FinCEN has designated each of the following as a primary money laundering concern and has imposed, or proposed imposing, special measures as follows:  Bank of Dandong and proposed regulation to impose the fifth special measure;  Banco Delta Asia SARL, including its subsidiaries, Delta Asia Credit Limited and Delta Asia Insurance Limited, and final regulation imposing fifth special measure;  Burma and final regulation imposing the fifth special measure.  See also exceptive relief allowing financial institutions to maintain correspondent accounts for Burmese banks under certain conditions;  Commercial Bank of Syria (includes its subsidiary, Syrian Lebanese Commercial Bank) and final regulation imposing the fifth special measure;  Democratic People's Republic of Korea and final regulation imposing the fifth special measure;  FBME Bank Ltd. and final regulation imposing the fifth special measure;  Halawi Exchange Co. and proposed regulation to impose the fifth special measure;  Islamic Republic of Iran and proposed regulation to impose the fifth special measure;  Kassem Rmeiti & Co. For Exchange and proposed regulation to impose the first and fifth special measures.Financial institutions should monitor FinCEN's 311 Special Measures website, or subscribe for updates at FinCEN's website in order to monitor the status of these or any other findings or special measures not listed here.


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