FinCEN proposes cutting off Banque Misr UAE under section 311

On 1 September 2026 FinCEN proposed to find Banque Misr UAE to be a financial institution operating outside the United States of primary money laundering concern under section 311 of the USA PATRIOT Act, and to bar U.S. institutions from keeping correspondent accounts for it (91 FR 56085). The proposal would add a new 31 CFR 1010.667.

Comments are due by 1 October 2026.

Who the target is

Banque Misr UAE means the five branches of Banque Misr in the United Arab Emirates: two in Dubai (Deira and Business Bay) and one each in Abu Dhabi, Sharjah and Ras Al Khaimah. The proposal says that "Egypt-based Banque Misr, and its branches and operations in countries other than the UAE are expressly excluded from the definition."

FinCEN calls the UAE operation a "critical access node to the U.S. dollar (USD) for Iranian illicit finance." It reports finding "103 potential Iranian shadow banking front companies transacting approximately USD 1.8 billion" through accounts there since January 2024, including "approximately USD 520 million over the most recent 12-month period." It also notes the bank "has three direct U.S. correspondent relationships through which it accesses the U.S. financial system."

What banks would have to do

The proposal uses special measure five, a prohibition on correspondent accounts. It applies to covered financial institutions as defined in 31 CFR 1010.605(e)(1), a group that includes banks, broker-dealers, futures commission merchants and introducing brokers, and mutual funds. A covered institution would have to:

1. not open or maintain a correspondent account in the United States for, or on behalf of, Banque Misr UAE;
2. take reasonable steps not to process a transaction for Banque Misr UAE through a foreign bank's U.S. correspondent account;
3. notify foreign correspondent account holders that it knows or has reason to believe serve Banque Misr UAE that they may not give it access to the account;
4. take reasonable steps, using the transaction records it already keeps, to identify any use of its foreign correspondent accounts by Banque Misr UAE; and
5. document that it sent the notices.

FinCEN says the proposal would not require reporting anything beyond what existing rules already require.

What it could mean

We'd guess very few community banks or credit unions hold a correspondent account for any foreign bank, let alone this one. For most of you, the direct obligation under the final rule would be close to nil. We still think this one deserves ten minutes, for two reasons.

First, the indirect access piece. Item 2 above is about transactions that reach you through someone else's correspondent account. If your bank sends or receives international wires through a larger correspondent, ask them how they plan to block Banque Misr UAE once a final rule is out, and whether they'll pass anything back to you. Your obligation would be "reasonable steps," and relying on a correspondent that screens for this is a reasonable step only if you've actually asked.

Second, the screening detail. Your wire filter needs to stop the UAE branches without catching the Egyptian parent, which the proposal expressly leaves out. A name match on "Banque Misr" would flag both. That is the kind of false positive that clogs a queue for months. Matching on the branch identifiers your correspondent uses is cleaner, and it's worth working that out now while the rule is still a proposal.

It's also worth adding this to your BSA risk assessment narrative under Iran exposure. If an examiner asks how you picked up section 311 actions, "we saw it the week it was proposed" is a better answer than "the vendor list updated eventually."