International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Wednesday, May 17, 2017

Update Regarding Imposition of Fifth Special Measure against FBME Bank, Ltd.

In its April 14, 2017 order granting FinCEN's motion for summary judgment, the U.S. District Court for the District of Columbia lifted the stay blocking the implementation of the March FinCEN-logo-shield31, 2016 Final Rule imposing a prohibition on opening or maintaining correspondent accounts for, or on behalf of, FBME Bank, Ltd. pursuant to Section 311 of the USA PATRIOT Act.  On April 28, 2017, the U.S. Court of Appeals for the District of Columbia Circuit denied FBME's motion for stay pending appeal.  Accordingly, the Final Rule is in effect.  FBME is appealing the district court's decision. 

I have been following this case for quite some time and intend to write a law review article about it as time allows.  See my previous post: 

Is FinCEN Becoming a Star Chamber? The Curious FBME case (2015)

FBME Bank Obtains Preliminary Injunction Against FinCEN (2015) 

FinCEN Cuts FBME Bank from Access to U.S. Financial System (2015)

FinCEN Re-Issues Order Against FBME Bank Ltd. Setting the Stage for the Court to Sort it Out (2016)

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