Imposition of Special Measure Regarding Al-Huda Bank as a Foreign Financial Institution of Primary Money Laundering Concern
Extension without change of a currently approved collection
No
Regular
03/31/2026
table that charts list comparision
Requested
Previously Approved
36 Months From Approved
09/30/2027
127
15,180
15
15,180
0
0
On July 3, 2024, FinCEN issued a final rule. As proposed in the NPRM, the final rule imposes special measure five, prohibiting U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Al-Huda Bank. Further, the rule requires that U.S. financial institutions notify their foreign correspondent account holders that they may not provide Al-Huda Bank with access to correspondent accounts maintained at the U.S. financial institution. The requirement is intended to ensure cooperation from correspondent account holders in preventing Al-Huda Bank access to the U.S. financial system. U.S. financial institutions are required to document compliance with the notification requirement. The information is used by Federal agencies and certain self-regulatory organizations to verify compliance with the rule.
US Code:
31 USC 5318A
Name of Law: Special measures for jurisdictions, financial institutions, international transactions, or types of
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 decreased from a uniform burden assignment of one hour in any given year in the prior renewals to either 0.25 hours or 0.05 hours, depending on the number of years elapsed since the first year in which a final rule implemented the given 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.
JointRenewal311SupportingStatement3_18_2026 Final.docx
Imposition of Special Measure Regarding Al-Huda Bank as a Foreign Financial Institution of Primary Money Laundering Concern