The Clearing House (TCH) along with the IIB filed a comment letter with the BCBS on its proposed revisions to the annexes on correspondent banking and account opening in its Sound management of risks related to money laundering and financing of terrorism guidelines. The letter argues that: (i) the definition of correspondent banking used in the Revisions is overly broad and should be narrowed to encompass only activities that generate the particular AML/CFT risks the Revisions seek to address; (ii) the Committee should clarify aspects of its risk management principles, acknowledge the limitations of the risk-based approach and encourage local authorities to permit banks to comply with regulatory expectations by applying the principles in good-faith; (iii) while further development of information-sharing tools may be helpful, a more meaningful approach to reducing due diligence costs is to permit correspondents to more fully rely on the supervision of their respondents and information provided by KYC utilities; and (iv) the Revisions’ provisions regarding banks’ monitoring and reporting obligations with respect to “manifestly meaningless or incomplete fields” in payment messages must be clarified.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions BPI Statement for the Record for House Oversight Hearing of FinCEN and the Office of Terrorism and Financial Intelligence
AML, Bank Secrecy Act and Sanctions BPI Statement for the Record on House Oversight Hearing of FinCEN and TFI
AML, Bank Secrecy Act and Sanctions BPI Welcomes FinCEN Rule Empowering Banks with Helpful Data to Fight Financial Crime
AML, Bank Secrecy Act and Sanctions FinCEN Must Preserve Beneficial Ownership Data Usefulness, Discourage Inappropriate Reporting Omissions
AML, Bank Secrecy Act and Sanctions BPI Responds to FinCEN Request for Comments Regarding Beneficial Ownership Information Reports
AML, Bank Secrecy Act and Sanctions Russian Oligarchs Hide Money in U.S. Only Reliable Data Can Stop Them.
More Posts by This Author
Security BPI and Joint Trades Comment on FCC’s Second Notice of Proposed Rulemaking on Illegal Text Messages
Regulatory Reporting and Accounting BPI Supports Call Report Revisions to Improve Securities Reporting Consistency