FinCEN wants Egypt's state bank cut out of the dollar in the Emirates, and it has put 103 front companies and $1.8bn behind the finding

Buried in the 113 documents the Federal Register put on public inspection at 08.45 on Monday is a 34 page filing that would close a state owned bank out of the dollar.

The Treasury's Financial Crimes Enforcement Network proposed a rule finding the five United Arab Emirates branches of Banque Misr, collectively Banque Misr UAE, to be a financial institution of primary money laundering concern under section 311 of the USA PATRIOT Act. The proposal would impose the fifth special measure: US financial institutions would be prohibited from opening or maintaining a correspondent account for the branches, would have to take reasonable steps not to process transactions for a foreign bank's US correspondent account where the transaction involves them, and would have to apply special due diligence across their foreign correspondent accounts to guard against the same thing happening indirectly.

Banque Misr is wholly owned by the government of Egypt. The Egyptian parent and every branch outside the Emirates are excluded from the finding by name.

The numbers behind the finding

FinCEN says it analysed Iranian shadow banking between June 2025 and June 2026 from non public information, and identified 103 potential Iranian shadow banking front companies moving approximately $1.8bn through accounts at Banque Misr UAE between January 2024 and June 2026. Approximately $520m of that falls in the most recent twelve months.

Set that against the size of the bank. FinCEN puts the branches at roughly $6bn in assets, one of 63 registered banks in the country, reaching the dollar through exactly three direct correspondent relationships with US institutions.

Three customers are named. Alpa Trading FZCO, a UAE company that the Office of Foreign Assets Control designated a Specially Designated Global Terrorist in September 2025, is recorded as having had over $32m in transactions processed between 2024 and 2025. Naba Alzaki Raw Materials Trading LLC, designated by OFAC in July 2026 for operating in Iran's financial sector, is recorded at over $29m between March and July 2025. Midas Oil Trading DMCC accounts for a single transaction of over $1m in January 2025.

What the agency is and is not saying

The document is a proposed finding and nothing in it is an adjudication. FinCEN states that it assumes a portion of the bank's business is legitimate, that it lacks full insight into the scope of those activities, and that it judges the legitimate business not to outweigh the risk. It also records that it is not aware of any investigation of Banque Misr UAE by any other country.

On the cost to American banks, the filing is blunt about how small it expects the disruption to be. Compliance would most commonly mean adding a name to screening tools that already exist. Cross border transaction volumes would not move. The branches could still do business in other currencies, so long as no covered US institution is in the chain.

Comments are due 30 days after the rule is published in the Federal Register, which the filed copy is scheduled for on September 1. FinCEN says it consulted the Federal Reserve Board, the OCC, the FDIC, the SEC, the CFTC, the National Credit Union Administration, the Secretary of State and the Attorney General before selecting the measure.