FinCEN's Banque Misr proposal names one bank and 103 front companies

On 1 September 2026 FinCEN proposed cutting the five United Arab Emirates branches of Egypt's state-owned Banque Misr off from American correspondent banking. The finding rests on roughly USD 1.8 billion that FinCEN says moved through 103 suspected Iranian front companies since January 2024. Comments close on 1 October.

The short version

• The proposal. FinCEN published a notice of proposed rulemaking on 1 September 2026 at 91 FR 56085, under RIN 1506-AB76. It finds the five UAE branches of Banque Misr to be "of primary money laundering concern".
• The subject. Banque Misr UAE is five branches of an Egyptian state-owned bank, wholly owned by the government of Egypt, holding about USD 6 billion in assets and three direct US correspondent accounts.
• The evidence. FinCEN says it identified 103 potential Iranian shadow banking front companies transacting approximately USD 1.8 billion through Banque Misr UAE accounts from January 2024 to June 2026.
• The measure. The fifth special measure under section 311 of the USA PATRIOT Act: a prohibition on US correspondent accounts, plus a duty to apply special due diligence to every foreign correspondent account.
• The status. Nothing is in force. This is a proposal. Written comments are due on or before 1 October 2026, and the document states no effective date.

Sanctioned states reach the dollar through companies registered to hide who owns them

FinCEN, the United States Financial Crimes Enforcement Network, says Iran evades sanctions using what it calls shadow banking networks. In a proposal published on 1 September 2026, it states that it previously identified approximately USD 9 billion of potential Iranian shadow banking activity moving through American correspondent accounts during 2024 alone.

A correspondent account is an account one bank holds at another so it can make payments in a currency or a country where it has no branch. Almost every dollar payment made outside the United States eventually touches one. That makes correspondent banking the chokepoint where American sanctions are actually enforced, and the thing a sanctioned economy most needs to reach.

FinCEN describes how the reaching is done. The networks "consist of Iran-based exchange houses and front companies" that let sanctioned Iranian entities get at dollars. The companies are not Iranian on paper. In FinCEN's words, they "are predominantly registered in third-country jurisdictions such as the UAE and the Special Administrative Region of Hong Kong (Hong Kong) to obscure beneficial ownership, disguise the origin of funds, and enable movement of proceeds linked to Iranian sanctions evasion and other illicit activity".

Beneficial ownership means the real people who ultimately own or control a company, as opposed to whoever is listed as the shareholder or director. The whole design turns on separating the two, because a bank that can see the second and not the first has no way to apply a sanction aimed at the first.

This proposal is one attempt at the problem, aimed at a single bank that FinCEN says the traffic passes through.

FinCEN counted 103 suspected front companies moving USD 1.8 billion since January 2024

FinCEN states that it "identified 103 potential Iranian shadow banking front companies transacting approximately USD 1.8 billion, using accounts with Banque Misr UAE from January 2024 to June 2026". Roughly USD 520 million of that fell in the most recent twelve months. FinCEN says it drew on non-public information covering June 2025 to June 2026.

Banque Misr UAE is five branches, in the United Arab Emirates, of Banque Misr, an Egyptian state-owned commercial bank wholly owned by the government of Egypt. The branches opened in August 1972 under the name Banque Du Caire and were fully acquired by Banque Misr in July 2007. FinCEN puts their assets at about USD 6 billion, notes they are one of 63 registered banks in the UAE, and says they hold three direct correspondent accounts in the United States.

Scale is the point of citing the asset figure. FinCEN says it observed the branches to have "a concerningly high percentage of potential Iranian shadow banking to assets in the data available and given the size of its assets". On FinCEN's own numbers, the suspected flow is a substantial fraction of the bank's balance sheet rather than a rounding error inside a large institution. Its conclusion is that Banque Misr UAE "serves as a significant conduit for Iranian shadow banking" and a "critical access node" to the American financial system.

Three companies are named in the document, and they are worth separating carefully, because they do not all rest on the same kind of evidence.

Company	Moved through Banque Misr UAE	Period	Basis in the proposal
Alpa Trading FZCO	over USD 32 million	2024 to 2025	OFAC designated under E.O. 13224, for supporting Ramin Jalalian, an Iranian currency exchanger working at the instruction of the Iranian defence ministry's supply division
Naba Alzaki Raw Materials Trading LLC	over USD 29 million	March to July 2025	OFAC designated in July 2026 under E.O. 13902, for operating in the financial sector of the Iranian economy
Midas Oil Trading DMCC	over USD 1 million	January 2025	Press reporting only, cited by FinCEN to a March 2026 newspaper article. Not a designation and not a FinCEN finding

The second row carries a lesson that outlives this proposal. Naba Alzaki moved money through the bank between March and July 2025. It was designated by OFAC, the American sanctions authority, in July 2026. For roughly a year, a screening check against the sanctions list would have returned nothing, because there was nothing to return.

That is not a failure of screening. It is what screening is: a test against a list of names that exists at the moment of the test. The 103 companies are, by FinCEN's description, chosen precisely because they are not on it.

The fifth special measure would impose three duties, and only one is about Banque Misr

Section 311 of the USA PATRIOT Act, codified at 31 U.S.C. 5318A, lets the Secretary of the Treasury find an institution to be of primary money laundering concern and then impose one of five special measures. FinCEN proposes the fifth, which allows a prohibition on correspondent or payable-through accounts, and would add it to the rules at 31 CFR 1010.667.

A payable-through account is a correspondent account whose customers can use it directly, which is why it is named alongside the ordinary kind. The proposed rule would require three things of what it calls covered financial institutions, meaning American banks and the other domestic institutions the rules reach.

1. Do 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 a foreign bank's American correspondent account where the transaction involves Banque Misr UAE.
3. Apply special due diligence to all foreign correspondent accounts, reasonably designed to guard against their use to process transactions involving Banque Misr UAE.

FinCEN considered the alternatives and rejected them in the document. It looked at the first four special measures, which mandate extra recordkeeping and reporting, and at the option of imposing conditions rather than a ban under the fifth. It concluded that "no measures short of full prohibition on correspondent or payable-through banking access would be sufficient", reasoning that where the volume of illicit funds is this large, a measure "intended to mandate additional information collection would likely be ineffective and insufficient".

On the effect elsewhere, FinCEN says the impact on the international payment, clearance and settlement system would be minimal, and that a prohibition "would not prevent Banque Misr UAE from conducting legitimate business activities in other foreign currencies, so long as a covered financial institution is not involved".

None of it is in force. This is a notice of proposed rulemaking, comments are due on or before 1 October 2026, and the document sets no effective date. FinCEN has proposed and withdrawn measures before, and it has also finalised them; nothing here settles which happens.

FinCEN calls compliance cheap because the named part is a name

FinCEN's own cost estimate in the 1 September 2026 proposal says a prohibition on correspondent banking with Banque Misr UAE "is expected to impose minimal additional compliance costs for covered financial institutions, which would most commonly involve adding Banque Misr UAE to preexisting sanctions screening and money laundering monitoring tools".

That is accurate, and it is the structural fact worth noticing. The proposal identifies conduct carried out by 103 companies. It names one bank and three of the companies. What a firm can act on mechanically is the one name, and adding a name to a list already being screened costs very little.

The 103 are not named, and on FinCEN's own account of how they are built they could not usefully be. They are registered in third countries specifically, in the document's words, "to obscure beneficial ownership". A list of them today would be a list of the ones already found.

The duty that reaches that part is the third one, and it is open-ended. It requires special due diligence across every foreign correspondent account, reasonably designed to catch transactions involving a bank whose involvement the intermediate parties are structured not to reveal. It has no list attached, and its cost is not the cost of adding a name.

The same shape appeared in the United Kingdom the day before. The National Crime Agency's Flash Alert on the A7 network, published 31 August 2026, describes shell companies registered abroad but controlled from Russia, with manufactured websites and matching network locations, and says plainly that this "enables A7 to avoid traditional anti-money laundering regulations and know-your-customer checks". Two agencies, two sanctions regimes, the same reliance on ownership that a registry records and a check cannot confirm.

It is also the counterpoint to a different FinCEN decision this year. In August the agency exempted US companies and US persons from reporting beneficial ownership to its own registry, and said it would delete what it had already collected. Here, in September, beneficial ownership opacity in third countries is the mechanism the proposal is written to address. Both are FinCEN's to reconcile, and the proposal does not attempt it.

Key takeaways

It is a proposal, not a rule.

Published 1 September 2026 at 91 FR 56085 under RIN 1506-AB76. Comments close 1 October 2026 and no effective date is stated.

The evidence is 103 companies and USD 1.8 billion.

FinCEN's figures, covering January 2024 to June 2026, including about USD 520 million in the last twelve months. FinCEN calls the activity "potential".

The subject is five branches, not a country.

The UAE branches of Egypt's state-owned Banque Misr, roughly USD 6 billion in assets, three direct US correspondent accounts.

Three duties, one of them open-ended.

No account for the bank; reasonable steps not to process transactions involving it; and special due diligence across every foreign correspondent account.

A screening list is a snapshot.

Naba Alzaki moved money through the bank in 2025 and was designated in July 2026. For about a year, a list check would have returned nothing.

Using Didit for the parts of this that are checks

FinCEN describes the mechanical part of compliance in its own words: adding a name to tools a firm already runs. That is worth being honest about, because it sets the boundary of what any vendor is selling here.

AML Screening at $0.20 per check is that step, and it is genuinely the cheap one. Ongoing AML Monitoring at $0.07 per user per year is the one this proposal argues for more strongly. Naba Alzaki was designated in July 2026 for activity in 2025, so a customer cleared at onboarding can become a designated party without doing anything visible. Only rescreening finds it. Business Verification (KYB) at $2.00 per check goes at the layer FinCEN says the concealment sits in, resolving a company to its registry record and its beneficial owners. The proposal supplies its own test: a subsidiary is a company whose voting stock is more than 50 percent owned, or otherwise controlled, by another. Transaction Monitoring at $0.02 per transaction supports the second duty, taking reasonable steps not to process a transaction that involves the named bank. Current prices are on the pricing page.

Four limits. The proposal is not in force and may change before any final rule. Whether a particular transaction "involves" Banque Misr UAE is a legal determination for the covered financial institution and its counsel, not for a vendor. Didit does not maintain the section 311 list and does not decide who is a covered financial institution. And screening finds a name, which is the part FinCEN itself calls minimal; the 103 unnamed companies are not a problem a check closes. Nothing here makes a firm compliant with 31 CFR 1010.667.

Frequently asked questions

What did FinCEN propose on 1 September 2026?

A notice of proposed rulemaking, published at 91 FR 56085 under RIN 1506-AB76, finding the five United Arab Emirates branches of Banque Misr to be of primary money laundering concern and proposing the fifth special measure under section 311 of the USA PATRIOT Act. It would prohibit US financial institutions from opening or maintaining correspondent accounts for Banque Misr UAE. It is a proposal, and comments close on 1 October 2026.

What is a section 311 special measure?

Section 311 of the USA PATRIOT Act, codified at 31 U.S.C. 5318A, lets the Secretary of the Treasury find that a jurisdiction, institution, account type or transaction type is of "primary money laundering concern", and then impose one or more of five special measures. The fifth allows a prohibition or conditions on opening or maintaining correspondent or payable-through accounts in the United States.

What evidence does FinCEN give?

FinCEN says it identified 103 potential Iranian shadow banking front companies transacting approximately USD 1.8 billion using accounts with Banque Misr UAE from January 2024 to June 2026, including roughly USD 520 million in the most recent twelve months. It says it analysed Iranian shadow banking between June 2025 and June 2026 using non-public information made available to it.

What would covered financial institutions have to do?

Three things under proposed 31 CFR 1010.667(b). Not open or maintain a correspondent account for Banque Misr UAE. Take reasonable steps not to process a transaction for a foreign bank's US correspondent account where the transaction involves Banque Misr UAE. And apply special due diligence to all foreign correspondent accounts, reasonably designed to guard against their use for transactions involving Banque Misr UAE.

Is the rule in force?

No. It is a notice of proposed rulemaking published on 1 September 2026, with written comments due on or before 1 October 2026. FinCEN states no effective date in the document, and the proposal may change before any final rule is issued.

Related reading

• The UK's first A7 alert — Shell companies built to pass KYC, described by the NCA the day before.
• The EU's ongoing monitoring obligation — Why a clear result at onboarding is not a durable answer.

Sources

1. Proposal of Special Measure Regarding Banque Misr UAE as a Financial Institution Operating Outside of the United States of Primary Money Laundering Concern — FinCEN, US Department of the Treasury · 91 FR 56085 · RIN 1506-AB76 · 1 September 2026 · every figure, quotation and duty in this post

Who wrote this

Tuan Nguyen — Growth · Didit

Writes about identity verification, fraud and compliance at Didit.

Last reviewed 1 Sep 2026 against the source above