The Clearing House (TCH) filed a comment letter with the BIS Committee on Payments and Market Infrastructures (CPMI) responding to its recent report providing technical measures to address reductions in correspondent banking. In the letter, TCH agreed that technical improvements to information sharing and similar anti-money laundering (AML) and counterterrorism financing tools may be helpful in improving access to correspondent banking services. However, TCH also stressed that it is just as important that policymakers and banks work together to better and more clearly define the roles and responsibilities of various stakeholders – including governments, supervisors and banks – for detecting, reporting and preventing money laundering through the global correspondent banking network. “This is not a simple question of compliance costs. What is also needed is for the public and private sectors to collectively reconsider regulatory requirements and supervisory expectations that are not reducing systemic AML/CFT risk but increasingly making it difficult, and in some cases effectively impossible, for correspondent banks to serve certain kinds of customers and markets,” said TCH’s General Counsel Jeremy Newell.