Proposal to Impose Special Measures Against the Lebanese Canadian Bank SAL

SIFMA provides comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury on the imposition of special measures against the Lebanese Canadian Bank SAL (LCB) as a financial institution of primary money laundering concern, RIN 1506-AB11.  The proposal would require covered financial institutions to: 1) provide notice to correspondent account holders that they may not provide LCB with access to the correspondent accounts maintained at the covered financial institution; and 2) take reasonable steps to identify any indirect use of their correspondent accounts by LCB to the extent that such use can be determined from transactional records maintained in the normal course of business.  SIFMA supports FinCEN’s determination to impose the special measures against LCB.