FinCEN's Banque Misr action reaches past the three U.S. banks that hold the accounts

Thirty months is the window FinCEN picked, January 2024 through June 2026 ^[3], and the shape of the flow inside it is more interesting than the headline total. About $520m of the suspected activity fell in the most recent twelve months the bureau reviewed ^[12], which leaves roughly $1.28bn spread across the preceding eighteen: about $71m a month early, about $43m a month lately, a decline on the order of 39% ^[2]. Two readings, and this desk cannot tell which is right from the proposal. Either the network was already routing around these five branches ^[2], or FinCEN simply has denser data on the earlier period. Both matter for remediation, because no amount of forensic lookback cleans up a flow that has already moved somewhere else.

The commercial question is narrower than the legal one. Three U.S. financial institutions hold the branches' correspondent accounts, FinCEN did not name them, and American Banker could not identify them either ^[8]; the comment period closes Oct. 1 and the file was empty as of Tuesday ^[13]. Nothing in the source tells us what those accounts earn, but the arithmetic on the other side is legible enough: the bureau says the branches are a significant conduit and describes the counterparties as potential front companies, without a court ruling on any of it ^[4], and the branches carried about $6.4bn in assets at the end of last year, against which the $1.8bn of flagged flow is roughly 28% ^[4]. An account that produces a fee schedule you cannot print next to that paragraph is a relationship banks would rather keep quiet than defend in public.

The part that spends other people's money is the second-order duty. Every U.S. bank, including the ones that never touched Banque Misr, would have to apply special due diligence across its entire foreign correspondent book and warn any foreign correspondent it knows or has reason to believe serves the Emirati branches that access is off ^[10], on top of taking reasonable steps to block transactions involving them ^[9]. When the trigger is "reason to believe" and the counterparties are Dubai free-zone shells built to obscure ownership ^[18], the cheap answer is a broad exit from that traffic rather than a careful one.

And this covers less of the problem than the language implies: $520m in a year is about 5.8% of the roughly $9bn FinCEN says Iranian shadow banking pushed through U.S. correspondent accounts in 2024 alone ^[3][11], different periods notwithstanding. So read it as a template with more entries to come. The view, held loosely: all three accounts close before the comment file does, and the final rule lands on a relationship that no longer exists. What would break that is a large U.S. bank filing a scope comment before Oct. 1, or the UAE central bank's urgent forensic examination ^[16] producing something FinCEN accepts and narrows against. Banque Misr has promised a response ^[14] but disputed no specific transaction ^[15] -- an opening posture more consistent with settling than with fighting.