FinCEN special measures in force

FinCEN's special measures are the most direct tool the US Treasury has against a foreign financial institution, jurisdiction or type of transaction it finds to be of primary money laundering concern. They range from extra recordkeeping to an outright ban on dealings. Since 2023 FinCEN has used them more often and more sharply, including against crypto exchanges, which means money transmitters and crypto firms, not only banks, now have to act on each one. This list sets out every measure in force or proposed that a US financial firm should screen against, with dates and what each requires, as at 9 November 2026. It is drawn from FinCEN's own special measures page and the Federal Register.

The three legal bases

The distinction matters in practice. A section 311 correspondent account prohibition mainly binds banks. A prohibition on transmittals of funds under sections 9714 or 2313a binds every covered financial institution, including money transmitters and crypto exchanges registered as MSBs.

Final measures in force

FinCEN's list also includes older final rules that remain relevant to banks: the Democratic People's Republic of Korea (2016), FBME Bank (2016), Bank of Dandong (2017), the Islamic Republic of Iran (2019), Burma (2004) and the Commercial Bank of Syria (2006). FinCEN has issued notices of exceptive relief for Burma and the Commercial Bank of Syria, so firms should read the current notice before acting on those two.

Proposed measures

A proposal is not yet binding, but a firm that keeps dealing with a named target during the proposal period takes on obvious risk. Most firms add proposed targets to enhanced monitoring as soon as the finding is published.

Recently withdrawn

On 6 October 2026 FinCEN withdrew its October 2023 proposal to treat international convertible virtual currency mixing as a class of transactions of primary money laundering concern. The withdrawal removes the proposed recordkeeping and reporting duty for mixing transactions. It does not change suspicious activity reporting, and exposure to mixers remains a risk factor in monitoring.

How quickly measures move

Section 311 measures usually start with a finding and a proposed rule, followed by a final rule months later. Section 9714 and 2313a measures can be imposed directly by order, with only a short gap before they take effect.

The lesson is that a firm cannot wait for a final rule before acting. A section 9714 order on a crypto exchanger can take effect within weeks of the announcement, so the screening and exposure review should start on the day it is published.

Special measures and sanctions compared

Special measures and OFAC sanctions are often confused. Both can stop a transaction, but they work differently, and a target can be subject to one, both or neither.

A complete programme screens against both and records which rule applies to each match.

How to read a FinCEN finding

Each finding explains why the target was chosen and often names affiliates, successor entities, wallet addresses or counterparties. Those details are the screening data. The MEXC order, for example, names seven current and former MEXC companies in five countries and describes its links to Garantex, Grinex and the A7 network. Compliance teams should extract every named entity and address into the screening system, not only the headline name, and keep a copy of the finding on file with the date it was reviewed.

What a money transmitter or crypto firm must do

For each final measure that prohibits transmittals of funds, the steps are the same.

• Screen. Add the target, its named affiliates and successors, and known wallet addresses to counterparty and payment screening.
• Block. Stop outgoing payments and withdrawals to the target from the effective date.
• Handle inbound. Write a procedure for funds received from the target, including crypto that cannot be rejected before it arrives.
• Review exposure. Look back at customer activity with the target and decide whether any SAR is needed.
• Check partners. Ask agents, correspondent banks, payment processors and liquidity providers how they comply.
• Record. Keep the review, decisions and screening changes for examiners and auditors.

Our guide to the MEXC order works through these steps for the most recent measure.

What a bank must do

Section 311 correspondent account prohibitions require banks to close or refuse correspondent accounts for the target and, in most final rules, apply special due diligence to foreign correspondent accounts to stop the target gaining indirect access. That usually means notifying foreign correspondents of the prohibition and reviewing their transactions for the target's activity. For transmittal prohibitions, banks follow the same steps as money transmitters, with particular attention to nested relationships and payment processors.

Building a standing procedure

FinCEN has acted often in 2026: MBaer in February, the CIBanco amendment in April, H-Pay in June, Banque Misr in August, the A7 sub-agents in October and MEXC in November. A firm that treats each as a separate project will keep repeating the same work. A standing procedure sets an owner, a timeline from publication to effective date, a screening update method, a template exposure review and a sign-off. It is also evidence that the AML programme responds to new risks, which state examiners and independent testers look for.

Our guide to money transmitter compliance requirements explains where special measures sit in the BSA programme, and our financial crime compliance support helps firms build and test these procedures. We update this list as FinCEN acts.