On April 23rd, the Treasury Department named two Lebanese exchange houses, Kassem Rmeiti & Co. For Exchange ("Rmeiti Exchange") and Halawi Exchange Co. ("Halawi Exchange"), as foreign financial institutions of primary money laundering concern under Section 311 of the USA PATRIOT Act. This is the first time the Department has used Section 311 against a non-bank financial institution. In conjunction with the findings that Rmeiti Exchange and Halawi Exchange are foreign financial institutions of primary money laundering concerns, Treasury's Financial Crimes Enforcement Network also issued an order, effective immediately and with a 120-day duration, that requires U.S. financial institutions to report information on any new or attempted transactions by Rmeiti Exchange and Halawi Exchange. Treasury also issued a notice of proposed rulemaking that, if adopted as a final rule, would continue the reporting requirement imposed by the order and prohibit any U.S. financial institution from opening or maintaining a correspondent or payable-through account that is used to process a transaction that involves Rmeiti Exchange and Halawi Exchange, effectively cutting off these exchanges from the U.S. financial system. Treasury Department Press Release.