SR 25-3: Imposition of Special Measures by the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN")
Updated supervisory guidance on FinCEN special measures framework under USA PATRIOT Act Section 311 and related legislation
Advisory Assessment
Impact. This guidance updates the Federal Reserve's reference framework for FinCEN special measures without creating new compliance obligations or changing existing BSA/AML requirements. Your institution continues operating under the same monitoring and implementation duties that apply when FinCEN designates entities or jurisdictions as primary money laundering concerns.
Risk. Examination teams will expect compliance officers to demonstrate current awareness of active special measures and show systematic monitoring of FinCEN's designation list. The most common gap occurs when institutions lack documented procedures for tracking new designations or fail to promptly implement correspondent account restrictions when the fifth special measure applies.
Recommended Action. Compliance should confirm that current BSA/AML monitoring procedures include regular review of FinCEN's special measures list and establish clear escalation protocols for when new designations emerge. Document this process in your BSA/AML program manual to satisfy examination expectations around systematic oversight.
Watch. Monitor FinCEN's website quarterly for new Section 311 designations, particularly those involving correspondent banking restrictions, as these require immediate operational response from your customer due diligence and transaction monitoring functions.
Classification
- Regulatory Program
- BSA/AML
- Doc Type
- Guidance
- Effective Date
- — Date not stated
- Days to Action
- —
- Comment Deadline
- —
- Published
- 2025-01-01
Urgency Basis
Guidance document with no new compliance obligations or deadlines - provides information about existing FinCEN special measures framework
Operational Context
Impact by Category
Key Requirements
Scoring Rationale
This is an informational supervisory letter that updates Federal Reserve supervised institutions on the existing FinCEN special measures framework. It provides background on authorities under Section 311 of USA PATRIOT Act and newer legislation but creates no new compliance obligations. The document supersedes SR 16-13 and serves primarily as reference material for understanding when and how special measures may be imposed. Impact is minimal as it only updates guidance documentation without changing underlying requirements.