Imposition of Special Measure Against Commercial Bank of Syria, Including its Subsidiary, Syrian Lebanese Commercial Bank, as a Financial Institution of Primary Money Laundering Concern.
ICR 202602-1506-001
OMB: 1506-0036
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Imposition of Special Measure
Against Commercial Bank of Syria, Including its Subsidiary, Syrian
Lebanese Commercial Bank, as a Financial Institution of Primary
Money Laundering Concern.
Extension without change of a currently approved collection
No
Regular
03/31/2026
Requested
Previously Approved
36 Months From Approved
07/31/2026
127
15,960
6
15,960
0
0
In March 2006, FinCEN issued a final
rule imposing the fifth special measure to prohibit U.S. financial
institutions from opening or maintaining a correspondent account
for, or on behalf of, the Commercial Bank of Syria, and requires
that U.S. financial institutions apply due diligence to
correspondent accounts they maintain on behalf of foreign financial
institutions that is reasonably designed to guard against the
indirect use of those accounts by the Commercial Bank of Syria. 31
C.F.R. § 1010.653(b)(2). U.S. financial institutions are required
under 31 C.F.R. § 1010.653(b)(2)(i)(A) to notify their foreign
correspondent account holders that they may not provide Commercial
Bank of Syria with access to correspondent accounts maintained at
the U.S. financial institution. The requirement is intended to
ensure cooperation from correspondent account holders in denying
Commercial Bank of Syria access to the U.S. financial system. U.S.
financial institutions are required under 31 C.F.R. §
1010.653(b)(3)(i) to document compliance with the notification
requirement. The information is used by Federal agencies and
certain self-regulatory organizations to verify compliance with 31
CFR § 1010.653.
US Code:
31
USC 5318A Name of Law: USA PATRIOT Act Pub. L. 107-56
When these OMB control numbers
were last renewed in 2023 and 2024, FinCEN estimated that because
approximately 15,000 to 16,500 U.S. financial institutions could
potentially maintain correspondent accounts for foreign banks, they
were all equally likely to incur recordkeeping burdens. In 2025,
FinCEN refined its burden assignment methods by distinguishing
between all covered financial institutions that could potentially
become respondents if they were to maintain a correspondent account
for a foreign bank and those that might reasonably be expected to
actually be respondents in a given year because they bear indicia
of already maintaining such accounts. As a result, in 2025, FinCEN
revised the estimated expected number of U.S. financial
institutions that maintain a correspondent account for a foreign
bank to 127. This is the primary reason for the change in the
burden estimate. In addition, FinCEN revised its burden methodology
to account for a staggered decrease in burden in the years
following the first year after the publication and implementation
of a Section 311 final rule imposing special measure five. Thus,
the average time per respondent has been decreased from a uniform
burden assignment of one hour in any given year in the prior
renewals to 0.05 hours given the number of years elapsed since the
first year in which the final rule implemented this imposition of
special measure five.
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.
03/31/2026
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