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
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.
03/31/2026
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Imposition of Special Measure Regarding Al-Huda Bank as a Foreign Financial Institution of Primary Money Laundering Concern