On July 23, FinCEN issued a final rule pursuant to Section 311 of the USA PATRIOT Act to impose “special measure five” against FBME Bank Ltd. (“FBME”), formerly known as the Federal Bank of the Middle East. Special measure five prohibits U.S. financial institutions from opening or maintaining correspondent accounts or payable through accounts for or on behalf of FBME. The action follows a July 17, 2014 notice of proposed rulemaking in which FinCEN stated that it had found FBME to be of primary money laundering concern under Section 311 and issued a related notice of proposed rulemaking (NPRM) proposing the imposition of special measure five against FBME. Supporting the proposed rule were the following factors: (i) FBME is used by its customers to facilitate money laundering, terrorist financing, transnational organized crime, fraud, sanctions evasion, and other illicit activity internationally and through the U.S. financial system; (ii) FBME has systemic failures in its anti-money laundering controls that attract high-risk shell companies, that is, companies formed for the sole purpose of holding property or funds and that do not engage in any legitimate business activity; and (iii) FBME performs a significant volume of transactions and activities that have little or no transparency and often no apparent legitimate business purpose. The final rule will be effective 30 days after its publication date in the Federal Register.