Banks Keep Snitching on Iran-Tied Foreign Buddies
Published Date: 3/28/2025
Notice
Summary
FinCEN is renewing its paperwork rules without any changes, asking U.S. banks to keep checking on foreign banks linked to Iranian and IRGC-designated groups. This helps keep bad money out of the system and supports national security. Banks and financial institutions should note the May 27, 2025 deadline to send in any comments, but no new costs or extra work are expected.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 4 costs, 0 mixed.
Mandatory CISADA Reports on Iran/IRGC Links
If FinCEN sends a written CISADA Request, a U.S. bank that maintains a correspondent account for a specified foreign bank must report specified information about that foreign bank's relationships with Iranian-linked financial institutions and IRGC-linked persons. The report must cover transfers or services processed within the preceding 90 calendar days and include names, account numbers, identifying information, and the approximate value in U.S. dollars of transactions.
Specific Reporting Deadlines for CISADA Responses
A U.S. bank must submit CISADA Reports within 45 calendar days of receiving a CISADA Request. If the foreign bank later notifies the U.S. bank of a new correspondent account, the U.S. bank must report that notification to FinCEN within 10 calendar days, and any foreign bank certification received after the 45-day window must be reported within 10 calendar days of receipt.
Five-Year Record Retention Requirement
U.S. banks must retain a copy of any CISADA Report and original or business-record-equivalent supporting documentation, including foreign bank certifications or responses, for a period of five years.
Scope and Estimated Annual Burden and Cost
FinCEN estimates up to 9,384 U.S. banks could be subject to the rule, but expects about 24 U.S. banks will respond annually, producing up to 72 CISADA Reports per year. FinCEN estimates the total annual burden is 156 hours and the total annual cost is $18,720 (using a composite wage of $120.07/hour).
Optional Certification Form and 365-Day Notification Promise
There is an optional CISADA certification form U.S. banks may use to obtain required information from specified foreign banks. Upon responding, a foreign bank is asked to agree to notify the U.S. bank if it establishes a new correspondent account for an Iranian-linked financial institution at any time within 365 calendar days from its initial response.
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