FinCEN Proposes Rule that Would Revoke Banque Misr UAE’s Correspondent Banking Access to U.S. Financial Institutions

When a U.S. financial institution extends correspondent banking privileges, it produces a decision to grant network access based on AML control adequacy. The proposed revocation suggests that Banque Misr UAE could not demonstrate — through contemporaneous, examinable records — that customer acceptance, beneficial ownership verification, and suspicious activity escalation decisions were made by identifiable owners with documented rationale. The general lesson is institutional: access grants are not one-time administrative events but ongoing control decisions that require engineered decision records, produced at the moment of approval and periodically reaffirmed with updated evidence. Without that artifact discipline, the regulator's power to revoke access becomes the only available remedy.