1、CRS INSIGHT Prepared for Members and Committees of Congress Legal SidebarLegal Sidebari i Treasury Proposes Rule That Could Deliver a “Death Sentence” to Chinese Bank October 30, 2017 In June, the Treasury Departments Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaki
2、ng (NPRM) to invoke the “Fifth Special Measure”a legal tool sometimes characterized as constituting a “death sentence” for targeted financial institutionsagainst the China-based Bank of Dandong (Bank). FinCEN claims that the Bank “acts as a conduit for North Korea to access the U.S. and internationa
3、l financial systems, including by facilitating millions of dollars of transactions for companies involved in North Koreas weapons of mass destruction and ballistic missile programs.” If FinCEN were to issue a final rule invoking the Fifth Special Measure against the Bank, certain domestic “covered f
4、inancial institutions” would be required to take steps to ensure that they do not provide financial services directly or indirectly to the Bank or its subsidiaries, which would essentially cut off the Banks access to the U.S. financial system. Although FinCEN has only issued a NPRM and has not yet i
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