FinCEN Proposes Rule Revoking Banque Misr UAE Correspondent Banking Access

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has proposed a rule to revoke Banque Misr UAE's correspondent banking access to U.S. financial institutions, according to a legal analysis published by Ballard Spahr LLP in The National Law Review. FinCEN determined that Banque Misr's UAE operations constitute a foreign financial institution of primary money laundering concern pursuant to Section 311 of the USA PATRIOT Act.

The regulatory measure is part of the U.S. Treasury's Operation Economic Outcast, an enforcement initiative launched in late August 2026 designed to sever financial lifelines supporting the Iranian regime. According to the proposed rule, Banque Misr UAE operates five branches in the country and holds three correspondent relationships with U.S. financial institutions, serving as an access node to U.S. dollars for Iranian illicit finance networks.

FinCEN estimated that between 2024 and 2026, Banque Misr UAE processed roughly $1.8 billion across 103 entities operating within Iranian shadow banking schemes. FinCEN further assessed that approximately $9 billion in potential Iranian shadow banking activity moved through U.S. correspondent accounts in 2024 overall, largely utilizing front companies registered in third-country jurisdictions, including the UAE, to obscure beneficial ownership.

The public comment period for the notice of proposed rulemaking is open through October 1, 2026. If finalized, the rule will prohibit U.S. financial institutions from opening or maintaining correspondent accounts for or on behalf of Banque Misr UAE, prohibit processing foreign correspondent transactions involving the bank, and require institutions to implement special due diligence measures.