TCH signed on to a letter to FinCEN with the ABA regarding the proposal to impose special measures against Banca Privada d’Andorra (BPA). The Director proposed to use the “fifth special measure” that authorizes FinCEN to identify direct correspondent accounts for BPA and requires all covered financial institutions to apply commercially reasonable measures to determine whether any existing or prospective customer is a branch, office or subsidiary of BPA. These institutions would be expected to apply increased due diligence to all foreign correspondent accounts initiated through BPA.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions FinCEN Should Focus on Flexibility, Clarity and Coordination When Defining AML Effectiveness
AML, Bank Secrecy Act and Sanctions BPI Submits Comment Letter to FinCEN Regarding AML Program Effectiveness
Bank Governance BPI Offers Recommendations to NY Financial Services Regulator on a Re-Proposed Regulation on Disclosure of Confidential Supervisory Information
Cybersecurity BPI Files Comment Letter with U.K. Banking Authorities in Response to Operational Resilience Proposals
Regulatory Reporting and Accounting BPI Submits Comment Letter to Banking Agencies on Revisions to Call Report
More Posts by This Author
FinTech & Innovation FinTech and Big Tech Companies Want the Benefits of Banking Without the Responsibilities. Regulatory Loopholes Could Let Them Succeed.
Bank Activities and Structure BPI Asks OCC to Furnish Data Used to Support Rushed Fair Access Proposal in FOIA Request
COVID-19 Relief BPI and Joint Coalition Urge House and Senate Leadership to Address PPP Forgiveness Process
Bank Capital and Stress Testing The Farmer and the Seed Corn: Why Lowering the CCyB and Imposing Dividend Restrictions Are Opposites