Imposition of Special Measure against Bank of Dandong as a Financial Institution of Primary Money Laundering Concern
Extension without change of a currently approved collection
No
Regular
03/31/2026
Requested
Previously Approved
36 Months From Approved
04/30/2027
127
15,876
6
15,876
0
0
FinCEN issued a final rule on November 8, 2017, imposing the fifth special measure to prohibit U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, Bank of Dandong. The rule requires that covered U.S. financial institutions apply due diligence to correspondent accounts they maintain on behalf of foreign financial institutions that is reasonably designed to guard against the indirect use of those accounts by Bank of Dandong. Covered U.S. financial institutions are required under 31 CFR 1010.660(b)(3)(i)(A) to notify holders of foreign correspondent accounts that they may not provide Bank of Dandong with access to such accounts. The requirement is intended to ensure cooperation from correspondent account holders in denying Bank of Dandong access to the U.S. financial system. Covered U.S. financial institutions are required under 31 CFR 1010.660(b)(4)(i) to document compliance with the notification requirement. The information is used by federal agencies and certain self-regulatory organizations to verify compliance with 31 CFR 1010.660.
When these OMB control numbers were last renewed in 2023 and 2024, FinCEN estimated that because approximately 15,000 to 16,500 U.S. financial institutions could potentially maintain correspondent accounts for foreign banks, they were all equally likely to incur recordkeeping burdens. In 2025, FinCEN refined its burden assignment methods by distinguishing between all covered financial institutions that could potentially become respondents if they were to maintain a correspondent account for a foreign bank and those that might reasonably be expected to actually be respondents in a given year because they bear indicia of already maintaining such accounts. As a result, in 2025, FinCEN revised the estimated expected number of U.S. financial institutions that maintain a correspondent account for a foreign bank to 127. This is the primary reason for the change in the burden estimate.
In addition, FinCEN revised its burden methodology to account for a staggered decrease in burden in the years following the first year after the publication and implementation of a Section 311 final rule imposing special measure five. Thus, the average time per respondent has been decreased from a uniform burden assignment of one hour in any given year in the prior renewals to 0.05 hours given the number of years elapsed since the first year in which the final rule implemented this imposition of special measure five.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
JointRenewal311SupportingStatement3_25_2026 Final.docx
Imposition of Special Measure against Bank of Dandong