Three duties under special measure five

FinCEN's notice of proposed rulemaking under section 311 of the USA PATRIOT Act finds the five United Arab Emirates-based branches of Banque Misr to be of primary money laundering concern. Although the text is not yet published in the Federal Register, it defines the binding step explicitly through special measure five.[1]

The draft prohibits U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Banque Misr UAE; requires reasonable steps not to process transactions involving the branches through foreign correspondent accounts; and adds special due diligence on foreign correspondent accounts reasonably designed to guard against transactions involving Banque Misr UAE.[1]

103 front companies and a split scope

FinCEN writes that 103 potential Iranian shadow banking front companies transacted approximately 1.8 billion dollars using accounts with Banque Misr UAE from January 2024 to June 2026, including approximately 520 million dollars over the most recent 12-month period. The text also cites flows on behalf of Iran's Ministry of Defense and Armed Forces Logistics and the Islamic Revolutionary Guard Corps through the example of Alpa Trading FZCO.[1]

The scope narrowing is explicit in the same document: Egypt-based Banque Misr and its branches and operations in countries other than the UAE are expressly excluded. Banque Misr UAE has only three direct U.S. correspondent relationships; the draft targets that narrow dollar line.[1]

Where the node sits

FinCEN assesses that Banque Misr UAE serves as a critical access node to the U.S. dollar for Iranian illicit finance; the strategic reading says the binding effect comes only from the branch-specific correspondent ban. The same volume could instead reflect routine compliance scrutiny of the institution's general anti-money-laundering weaknesses.[1]

The text requests 30 days for comments after Federal Register publication; leaving Egypt-based Banque Misr outside the draft while targeting only the UAE branches shows in today's text a narrowed geographic scope.[1]