NIAC Submits Public Comment on Proposed Rule to Address Banking Discrimination

In July 2024, the Department of Treasury and the Financial Crimes Enforcement Network put forth a proposed rule to strengthen and modernize the way that financial institutions conduct their Anti-Money Laundering (AML) and Countering the Finance of Terrorism (CFT) Programs. To date, these are the very programs which have contributed to the ongoing pattern of de-risking, or banking discrimination, against the Iranian and Iranian-American community. These regulations, along with sweeping U.S. sanctions against Iran and legislation like the Patriot Act, have led to no-notice bank account freezes and even closures, causing immense disruption to the lives of Iranians and Iranian Americans solely on the basis of their national heritage.

For years, NIAC has sought to elevate this issue and work with both banks as well as the Department of Treasury to better safeguard minority communities from discriminatory banking practices. As such, this proposed rule signifies a progressive step in the right direction toward that end, though much remains to be accomplished to effectively eradicate de-risking overall.

In response to the proposed rule, NIAC submitted a public comment detailing the history of our work on this issue as well as how the Department of Treasury can expand upon its proposed rule to better address de-risking. The comment is included below: