The Clearing House (TCH) published a final updated version of its Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking. The guiding principles, which were initially published in 2002, are intended to provide guidance to U.S. banks engaged in foreign correspondent banking and to assist U.S. banks in implementing key anti-money laundering (AML) procedures. The updated 2016 guidelines address changes in the AML and sanctions statutes, orders, rules and regulations; guidance clarifying the U.S. government’s expectations of U.S. bank’s AML policies and procedures in correspondent banking; guidance provided by international organizations; and industry enhancements to correspondent banking practices. Some of the areas covered by the principles include: establishment of foreign correspondent banking accounts, including due diligence and enhanced due diligence; risk assessment of foreign correspondent banking customers; identification and reporting of suspicious activity; increased transparency for cross-border payments; sanctions compliance; information sharing; and government requests for information.
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