FinCEN Opens Comment Period on Iran Sanctions Oversight

On 28 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a 60-day notice in the Federal Register, inviting public comment on the renewal of an existing Office of Management and Budget (OMB) control number associated with foreign bank reporting requirements under the Bank Secrecy Act (BSA).

The regulations, set out in 31 CFR 1060.300, require US banks maintaining correspondent accounts for specified foreign banks to collect and report information when requested by FinCEN. Specifically, banks must inquire whether their foreign correspondent institutions have conducted transactions or provided financial services to entities linked to Iran. These include Iranian-linked financial institutions and individuals or entities associated with the Islamic Revolutionary Guard Corps (IRGC), both designated under the International Emergency Economic Powers Act (IEEPA).

This reporting obligation plays a vital role in combatting illicit finance networks by ensuring transparency in cross-border correspondent banking relationships, particularly in relation to sanctions evasion and terrorism financing.

FinCEN is requesting industry input on the existing regulatory requirements and associated burden estimates. Comments must be submitted on or before 27 May 2025.

This notice provides a valuable opportunity for financial institutions and compliance professionals to influence future regulatory practice. FinCEN encourages all stakeholders to review the notice and submit feedback to help enhance the effectiveness and efficiency of this important reporting regime.

Read the notice here.