Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial Institutions Designated under IEEPA and IRGC-Linked Persons Designated under IEEPA (31 CFR 1060.300)
Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial Institutions Designated under IEEPA and IRGC-Linked Persons Designated under IEEPA (31 CFR 1060.300)
Extension without change of a currently approved collection
No
Regular
Approved without change
09/17/2025
07/31/2025
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
09/30/2028
36 Months From Approved
09/30/2025
72
0
1,040
156
0
1,820
0
0
0
The Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) amended the Iran Sanctions Act of 1996 by expanding economic sanctions against Iran, and required the Secretary to prescribe regulations to establish one or more specific requirements for U.S. financial institutions maintaining correspondent accounts for foreign financial institutions, in connection with certain statutory sanctionable activities. On October 11, 2011, pursuant to section 104(e) of CISADA, FinCEN issued a final rule requiring a bank operating within the United States (U.S. bank) that maintains a correspondent account for a specified foreign bank to make certain inquiries and report certain information about transactions or other financial services provided by that foreign bank. U.S. banks are only required to report this information upon receiving a specific written request from FinCEN (CISADA Request).
Upon receiving a CISADA Request, a U.S. bank that maintains a correspondent account for a specified foreign bank is required to make certain inquiries and provide a report to FinCEN (CISADA Report) of: (i) any correspondent account maintained by such foreign bank for an Iranian-linked financial institution designated under the International Emergency Economic Powers Act (IEEPA) (âIranian-linked Financial Institutionâ); (ii) any direct or indirect transfer of funds for or on behalf of an Iranian-linked financial institution processed by such foreign bank within the preceding 90 calendar days, other than through a correspondent account; (iii) and any direct or indirect transfer of funds for or on behalf of an Islamic Revolutionary Guard Corps (IRGC)-linked person designated under IEEPA (âIRGC-linked Personâ) processed by such foreign bank within the preceding 90 calendar days.
There is an optional CISADA certification form U.S. banks may use to obtain the necessary information from specified foreign banks.
A U.S. bank must maintain a copy of any CISADA Report and the original or any business record equivalent of any supporting documentation for a CISADA Report, including a foreign bank certification or other responses to an inquiry for a period five years.
The estimated total annual burden hours decreased by 1,664 hours from 1,820 hours in 2022 to 156 hours in 2025. The burden per CISADA-related report from U.S. banks that maintain correspondent accounts for specified foreign banks remained at 3 hours per response. The burden per CISADA-related report from U.S. banks that do not maintain correspondent accounts for specified foreign banks remained at 30 minutes per response. The decrease in burden is a result of a decrease in the estimated number of responses per potential respondent from 1,040 in 2022 to 72 in 2025, although the estimate of the number of entities that maintain correspondent accounts for foreign banks increased from 52 in 2022 to 72 in 2025. FinCEN believes that the estimate for the number of responses per entity for 2025 is a more accurate figure, as each U.S. bank will only provide one response to each request, and not every U.S. bank maintaining a foreign correspondent account will be required to respond to a request every year. Furthermore, FinCEN has exercised this authority on an infrequent basis, and believes that the updated burden estimate, now divided over the three-year renewal period, is a better reflection of the actual anticipated burden stemming from these requests.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
CISADA Reports when a U.S. bank does not maintain an account for a foreign bank