On September 20, 2016, the U.S. District Court for the District of Columbia remanded to FinCEN a Final Rule issued under Section 311 that would have severed FBME Bank Ltd. from the U.S. financial system. In its memorandum opinion, the court stated that FinCEN had not meaningfully responded to FBME’s comments regarding FinCEN’s treatment of aggregate Suspicious Activity Report (SAR) data. FinCEN today submitted for publication in the Federal Register a Supplement to the Final Rule that responds to FBME’s comments.