FinCEN issues its first § 5318(k) subpoena in probe of Greek bank's potential Iran ties
FinCEN says it issued its first administrative subpoena under 31 U.S.C. § 5318(k) of the Bank Secrecy Act to advance an investigation into a Greek bank's potential ties to Iran and its proxies.
The US Treasury's Financial Crimes Enforcement Network (FinCEN) said on 21 October 2026 that it is investigating a Greek bank's potential ties to Iran and its proxies. FinCEN said it is acting in close coordination with European partners, including in Greece. The release does not name the bank.
As part of that investigation, FinCEN said it made its first issuance of an administrative subpoena under 31 U.S.C. § 5318(k) of the Bank Secrecy Act. The release does not describe the scope of the subpoena or who received it.
FinCEN also said it has issued multiple requests for information concerning banks' relationships with Iranian financial institutions that the Office of Foreign Assets Control (OFAC) has designated.
FinCEN announced these steps in the same release that reported Treasury sanctions on Karnakis and Karnakis, a law firm based in Panama and Greece that the release says has supported illicit Iranian shipping, and on shipping agents based in Singapore and the UAE. The actions are part of Treasury's Operation Economic Outcast.
Why it matters to AML professionals
When a regulator investigates a foreign bank for possible links to a sanctioned country, banks that deal with that foreign bank can face questions about the relationship. AML professionals in correspondent banking should keep clear records on foreign respondent banks with possible exposure to Iran and be ready to answer requests for information quickly.
Red flags in this case
- A foreign respondent bank processes payments for shipping agents, ship managers or law firms linked to vessels carrying Iranian oil
- Payments routed through a respondent bank name companies that share addresses or directors with sanctioned entities
- A respondent bank gives incomplete or slow answers to requests for information about its customers' Iran exposure
- Wire messages show frequent amendments to party names or missing originator or beneficiary details
If this landed in your queue
- Check whether any foreign respondent bank in your portfolio is in the country or region named in the investigation, and review its recent activity
- Screen the parties in recent correspondent payments against the latest OFAC designations
- Send a request for information to the respondent bank about the underlying customers and the purpose of unusual payments
- Escalate to your sanctions and legal teams and consider a suspicious activity report if the answers do not explain the activity
Key terms
- Administrative subpoena
- A legal demand for documents or records issued by a government agency itself, without going to a court first.
- Request for information (RFI)
- A written request for details about customers, accounts or transactions, used to understand activity or a relationship.
- Correspondent account
- An account a bank keeps for a foreign bank so that the foreign bank can make and receive payments in another country.
Interview angle
A regulator tells you it is investigating one of your foreign respondent banks for possible sanctions exposure. What do you do first?
Explain that you would pull the full transaction history for the relationship, screen all parties against current sanctions lists, send a request for information to the respondent, involve legal and sanctions teams, and assess whether to restrict or exit the relationship and file a report.
Sources
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