The Clearing House Association submitted a letter to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) commenting on FinCEN’s proposal to impose a special measure on Lebanese Canadian Bank, which FinCEN has designated as a financial institution of primary money-laundering concern. The letter supports the proposed special measure but states that (i) the notice requirement could be made less burdensome by allowing banks to put in the terms and conditions governing their correspondent banking relationships a requirement that the correspondents use their account in a manner that is consistent with U.S. law, and (ii) FinCEN should promptly review the status of the designation as a financial institution of primary money-laundering concern if there is a change of ownership, organization or control.