On March 31, 2016, following a voluntary remand ordered by the United States District Court for the District of Columbia, FinCEN published in the Federal Register a Final Rule imposing the fifth special measure against FBME Bank Ltd. (FBME), which was scheduled to take effect on July 29, 2016. On July 22, 2016, the Court ordered that implementation of the Final Rule be stayed until further notice from the Court, noting that the Court required additional time beyond the Final Rule’s effective date to complete its review of the parties’ motions in the litigation.