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Banks Must Cast Net Wide When Researching Correspondents’ AML Programs

By Brian Orsak

Corrections Appended As any compliance officer knows, vetting a banking correspondent relationship is no simple matter. Initial evaluations of another institution's anti-money laundering program can be long, the cost high and reviews perpetual. Section 312 of the Patriot Act mandates that U.S. financial institutions conduct enhanced, or greater, diligence when evaluating correspondent relationships for money laundering risk. The U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) defines such relationships as any established for a foreign institution to receive deposits, make payments or handle financial transactions. Under final 312 rules issued in August, financial institutions must obtain "reasonably available" information about...

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