On May 23, 2025, FinCEN issued exceptive relief to covered financial institutions for requirements pursuant to its rule imposing special measures against the Commercial Bank of Syria. The exceptive relief permits covered financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria (CBoS) under certain conditions.
The exceptive relief was issued by FinCEN after the OFAC issued immediate sanctions relief for Syria in line with the President’s announcement for the cessation of all sanctions on Syria. FinCEN has determined that the following exception is appropriate:
The provisions of paragraphs (b)(1) and (2) of section 31 C.F.R. 1010.653 shall not apply to a correspondent account that is established, maintained, administered, or managed in the United States by a covered financial institution (as defined in 31 C.F.R. 1010.653(a)(3)) for, or on behalf of, CBoS. 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.
FinCEN’s full issuance can be found here.
