Internal Investigation Report Stresses Lack of Intentional Misconduct – But the Investigation May Broaden - Westpac Banking Corporation (“Westpac”), Australia’s second largest retail bank, has been besieged by serious...more
Indictment Again Highlights the Role of Correspondent Banking in Money Laundering - On May 28, 2020, the U.S. Department of Justice (“DOJ”) unsealed a 50-page indictment against 28 North Korean and 5 Chinese bankers...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
AML Scandals Seem to Inevitably Spawn Investor Lawsuits - As we recently blogged, Westpac, Australia’s second-largest retail bank, has been embroiled in a scandal arising from approximately 23 million alleged breaches of...more
“Rejected Transactions” Reporting: Additional Compliance Obligations for Financial Institutions; New Compliance Obligations Businesses, Nonprofits, Inividuals, and Foreign Entities Owned or Controlled by U.S. Persons - The...more
The Financial Action Task Force has launched an online private sector survey on correspondent banking and the usefulness of its 2016 Guidance on correspondent banking services. The Guidance was published in response to...more
The Financial Stability Board has published an update to its correspondent banking data report. The latest data report updates the data report the FSB published in July 2017 alongside a report for the G20 on progress made on...more
The Wolfsberg Group has published an updated version of its Correspondent Banking Due Diligence Questionnaire (dated February 22, 2018). The CBDDQ has been enhanced and expanded in line with regulatory expectations on...more
FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more
The Wolfsberg Group has published two new standards, the Correspondent Banking Due Diligence Questionnaire (CBDDQ) and the revised Payment Transparency Standards. The Wolfsberg Group was established in 2002 and comprises...more
The Financial Stability Board published an updated progress report outlining its action plan to assess and address the decline in correspondent banking. Correspondent banking relationships enable banks to access financial...more
Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more
On October 5, 2016, the Office of the Comptroller of the Currency (the “OCC”) issued risk management guidance that addresses periodic reevaluations of risks associated with foreign correspondent banking accounts. The guidance...more
The U.S. Department of the Treasury and four U.S. federal banking regulators have issued the "Joint Fact Sheet on Foreign Correspondent Banking" in an effort to clarify enforcement priorities regarding Anti-Money Laundering...more
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...more