Financial Crimes Enforcement Network, Exception to Prohibition Imposed by Section 311 of the USA PATRIOT Act against the Commercial Bank of Syria, issued 23 May 2025
Source ID
SRC-201
Citation
Financial Crimes Enforcement Network, Exception to Prohibition Imposed by Section 311 of the USA PATRIOT Act against the Commercial Bank of Syria, issued 23 May 2025
URL or path
https://www.fincen.gov/news/news-releases/fincen-exceptive-relief-financial-institutions-regarding-commercial-bank-syria; research/SRC-201_FinCEN_CBoS_exceptive_relief_2025-05-23.pdf; news release at research/SRC-201_FinCEN_news_release.html
Type
Primary instrument, United States regulatory relief
Hierarchy tier
1
Published
2025-05-23
Accessed
2026-08-17
Snapshot
Retrieved 17 August 2026 from fincen.gov, HTTP 200, one page, 388,795 bytes
Claims
CH6 the US correspondent banking position for the Commercial Bank of Syria; the surviving section 311 finding
Status
READ
Version history
The register keeps changing after the book is fixed in print. Each entry below was added to this row in the order shown.
READ IN FULL 17 August 2026, ONE PAGE, AND IT IS THE CHAPTER'S BEST SINGLE EXHIBIT ON THE GAP BETWEEN LAWFUL AND POSSIBLE. ISSUED 23 MAY 2025, the SAME DAY as General Licence 25 and the Caesar Act waiver named in EO 14312 section 1, so three US actions fall on one day. WHAT IT DOES: exceptive relief under 31 U.S.C. 5318(a)(7) and 31 C.F.R. 1010.970, disapplying paragraphs (b)(1) and (2) of 31 C.F.R. 1010.653 to a correspondent account established, maintained, administered or managed in the United States by a covered financial institution for or on behalf of the Commercial Bank of Syria. WHAT IT EXPRESSLY DOES NOT DO, AND THIS IS THE POINT: the section 311 rule itself STANDS. The finding is not withdrawn. 'Nothing in this grant of exceptive relief shall waive or alter the due diligence obligations for covered financial institutions set forth under Section 312 of the USA PATRIOT Act and its implementing regulation 31 C.F.R. 1010.610.' AND IT IS REVOCABLE AT WILL: 'an exception is issuable or revocable in the sole discretion of the Secretary of the Treasury, based on the circumstances to which the exception applies.' SO A BANK WEIGHING A CBoS CORRESPONDENT ACCOUNT IS NOT ASKING WHETHER IT IS LAWFUL TODAY. It is asking whether it will remain lawful, and whether its enhanced due diligence under section 312 can be satisfied against a bank whose 311 finding is still on the books. That is a risk fact, not a permission fact, and it is the chapter's subject stated by the regulator. SCOPE OF THE RELIEF'S DEFINITION: CBoS is as defined in 31 CFR 1010.653(a)(1) and INCLUDES 'any branch, office, or subsidiary of Commercial Bank of Syria operating in Syria or in any other jurisdiction, including SYRIAN LEBANESE COMMERCIAL BANK'. FinCEN records that it consulted the Department of State. NOT RETRIEVED AND NAMED AS A ROUTE: 31 C.F.R. 1010.653 itself, and the original section 311 finding against CBoS, which would give the date and grounds of the measure the relief leaves standing.
PUBLIC ADDRESS RECOVERED 31 AUGUST 2026 from the publisher's own canonical or og:url declaration inside the archived capture, or from another field of this row, and NOT from a fresh retrieval. The address is what the publisher stated the document's location to be at the time this project captured it; it has not been re-fetched since. Recorded so the works cited head-note count can move and so a reader has a route.