Newsflash: US Government Issues Guidance to Reassure US Banks Involved in Foreign Correspondent Relationships

September 01, 2016

The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a Joint Fact Sheet on Foreign Correspondent Banking. The guidance highlights the U.S. government’s twin goals of expanding access to the U.S. financial system and protecting it from abuse, and provides transparency with respect to: (i) the expectations of U.S. enforcement authorities regarding due diligence obligations of U.S. depository institutions that maintain correspondent accounts for foreign financial institutions (FFIs); and (ii) the circumstances that merit enforcement actions for violations of AML and sanctions laws.

In a blog post issued contemporaneously with the Fact Sheet, senior U.S. Treasury Department officials made clear that the goal of U.S. authorities is to “implement a fair and effective regime when it comes to enforcement of AML and sanctions violations. Importantly, this regime is not one of ‘zero tolerance.’”

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