The risks posed by correspondent banking are of concern to regulators, bankers, and broker-dealers in securities alike. U.S. financial institutions have faced severe penalties as a result of their foreign correspondent banks having weak BSA/AML compliance programs. The various sections of the USA PATRIOT Act and implementing regulations in the Bank Secrecy Act have been in final form of a number of years now. This course will discuss not so much the regulations but rather the practical applications of the regulatory requirements, with a particular emphasis on nested accounts. This course is designed for both U.S. financial institutions offering correspondent banking as well as for foreign financial institutions which have or are seeking U.S. correspondent banking relationships. U.S. financial institutions will acquire practical knowledge to apply to their correspondent compliance programs. Foreign financial institution will have a much better understanding and appreciation for the requirements of the correspondent bank and be better able to demonstrate its compliance program and contract requirements.
Prior to beginning the course participants should complete the pre-course reading list. Anticipated reading time: 5-7 hours.
Who Should Attend
•AML/CFT Compliance Personnel
•Regulators/Supervisors Of Financial Institutions
•1 Day In-Person Training
Chapter 1: History and Regulatory Expectations
Chapter 2: Correspondent Banking Overview
•Non-Banking Financial Institutions
•Money Transmitters and MSBs
Chapter 3: Risk Rating Methodology
Chapter 4: Due Diligence Programs
Chapter 5:Transaction Monitoring
Chapter 7: Contract Considerations