FinCEN's Banque Misr proposal names one bank and 103 front companies
Blog post from Didit
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FinCEN proposed on 1 September 2026 to designate the five UAE branches of Egypt’s state-owned Banque Misr as institutions of primary money laundering concern and bar U.S. financial institutions from maintaining correspondent or payable-through accounts for them under the fifth special measure of Section 311 of the USA PATRIOT Act. The proposal cites approximately $1.8 billion in transactions involving 103 potential Iranian shadow-banking front companies from January 2024 through June 2026, arguing that companies registered in jurisdictions such as the UAE and Hong Kong can obscure beneficial ownership and help sanctioned Iranian actors access the dollar system. If finalized, the rule would also require U.S. institutions to take reasonable steps to avoid processing relevant transactions through foreign correspondent accounts and to apply special due diligence across those accounts. FinCEN describes the direct screening burden of adding Banque Misr UAE to existing systems as limited, while the broader due-diligence obligation presents a more open-ended challenge because suspected front companies may be unidentified or not yet sanctioned. The proposal is not effective, accepts comments through 1 October 2026, and may be modified, withdrawn, or finalized; the source also uses the proposal to discuss the limits of sanctions screening, the importance of ongoing monitoring and beneficial-ownership verification, and related compliance services.
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