What is correspondent banking AML risk?

In order to understand what correspondent banking AML risk is, let’s break it down.

What are correspondent banks?

The definition of correspondent banking is: Banks in a country that are set up to provide services for another bank or financial institution in a foreign country. The services provided by a correspondent bank include money transfers, currency exchange, trade documentation and business transactions. Typically, in a correspondent banking relation, two banks in two different countries enter into an agreement to open a correspondent account (Nostro or Vostro account), which enables a domestic bank to make payments or do money transfers in local currency on behalf of a foreign bank. An example of a correspondent banking transaction is given below.

  1. A corporate customer of a bank in one country wants to pay for products purchased from a foreign supplier.
  2. The customer approaches its domestic bank and instructs to make the payment (in foreign currency).
  3. The domestic bank determines the local currency value of the foreign products purchased and deducts the same from its customer’s account.
  4. The domestic bank then instructs its correspondent bank in the supplier’s country to pay the supplier in the local currency from the domestic bank’s correspondent account.

Correspondent banks are most likely to be used by domestic banks to service transactions that either originate or are completed in foreign countries. Domestic banks generally use correspondent banks to gain access to foreign financial markets and to serve international clients without having to open branches abroad.

What is an example of this?

For example, let’s say you live in the U.S. and go to your local bank to wire funds to a friend in Spain. An employee at the bank simply searches the SWIFT network to find a correspondent bank that has an agreement in place with the financial institution in Spain. Then, the correspondent bank facilitates the transaction.

Money laundering through correspondent banking

Money laundering, the act of concealing the illegal nature of ill-gotten money, is an international problem. According to the UNODC, the amount of money being laundered across the globe every year is equivalent to 2-5% of global GDP, or USD800 billion – USD2 trillion. Financial crime impacts the economies and communities of all countries, irrespective of their financial health and stage of development.

Money laundering has a global nature as many criminals make use of international transaction options in the layering or integration stages. Correspondent banks play an important role in facilitating cross-border money laundering transactions. Criminals make use of the services of correspondent banks without proper anti-money laundering (AML) controls to pass on their criminal proceeds to jurisdictions where they can use them in a hassle-free manner. Here, we are trying to understand correspondent banking AML risk in detail and national and international regulations to mitigate correspondent banking AML risk.

Correspondent banking AML risk

Correspondent banking is an essential part of the global payment system and international trade depends largely on it. However, these facilities are often abused to facilitate money laundering and terrorist financing. Mitigation of correspondent banking AML is often a difficult task as the domestic bank carrying out the transaction on behalf of a foreign bank has to rely on the foreign bank’s abilities in identifying the customer, determining the real owners, and monitoring correspondent banking transactions for risks. Often, a foreign bank’s AML compliance programs may not be sufficient to meet the AML requirements of a domestic bank.

There have been reports that foreign correspondent accounts have been used by drug traffickers and other bad actors to launder money. Further, shell companies have often been used in the layering process to hide the actual ownership of accounts at foreign correspondent financial institutions. Due to a large amount of funds, many transactions, many AML fraud schemes, and a domestic bank’s unfamiliarity with the foreign correspondent bank’s customers, it is easy for criminals to conceal the source and use of ill-gotten funds. Therefore, governments in a correspondent banking relationship must ensure complementary and robust anti-money laundering / counter-terrorist financing (AML/CTF) measures to safeguard their financial systems.

 

The KYC challenges for correspondent banks

Know-your-customer (KYC) due diligence is an essential element of banking, including correspondent banking. Banks that enter into correspondent banking relationships need to be sure that banks in the chain have correct controls and governance in place, and that their KYC, AML and other due diligence procedures are strong.

Customer due diligence requires that correspondent banks identify and understand their respondents’ banking activities and know if the respondents maintain additional correspondent banking relationships.

FATF guidelines on correspondent banking AML risk

FATF, the international AML/CFT watchdog, recommended various measures to counter money laundering via correspondent banking. FATF noted that “financial institutions have increasingly decided to avoid, rather than to manage, possible money laundering or terrorist financing risks, by terminating business relationships with entire regions or classes of customers”. This so-called ‘de-risking’ practice “can result in financial exclusion, less transparency and greater exposure to money laundering and terrorist financing risks”, according to the watchdog.

FATF advocates the application of the risk-based approach to correspondent banking relationships. It recommended the following measures to counter money laundering via correspondent banking.

  • Due diligence on the respondent institution: FATF recommends additional due diligence measures to be applied to cross-border correspondent banking relationships. Such additional measures are appropriate because cross-border correspondent banking relationships are seen to be inherently higher risk than domestic correspondent customer relationships.
  • Developing an understanding of the respondent institution’s business: The correspondent institution should also gather sufficient information to understand the nature of the respondent institution’s business in line with the risks identified.
  • Verifying respondent institution’s information and assessing/documenting higher risks: When establishing new correspondent banking relationships, the correspondent institution may obtain information directly from the respondent institution. However, this information needs to be verified with independent sources of information such as corporate registries, registries maintained by competent authorities on the creation or licensing of respondent institutions, and registries of beneficial ownership.
  • Ongoing due diligence on the respondent institution: Correspondent institutions are required to conduct ongoing due diligence of the correspondent banking relationship, including periodical reviews of the CDD information on the respondent institution.
  • Ongoing transaction monitoring: Ongoing AML monitoring of the correspondent banking account activity is needed for compliance with targeted financial sanctions and to detect any changes in the respondent institution’s transaction pattern that may indicate unusual activity, or any potential deviations from the correspondent relationship.
  • Request for information about transactions: Where the monitoring system of the correspondent institution flags a transaction, which could signal unusual activity, the correspondent institution should have internal processes to further review the activity, which may involve requesting transaction information of the respondent institution in order to clarify the situation and possibly clear the alert.
  • Clear terms governing the correspondent banking relationship: Correspondent institutions can manage their risks more effectively from the outset by entering into a written agreement with the respondent institution before correspondent services are provided.
  • Ongoing communication and dialogue: It is important for correspondent institutions to maintain an ongoing and open dialogue with the respondent institution(s) including helping them understand the correspondent’s AML/CFT policy and expectations, and when needed, engaging with them to improve their AML/CFT controls and processes.
  • Adjusting the mitigation measures to the evolution of risks: The level and nature of AML/CFT risk may fluctuate over the course of any relationship and adjustments should be made in the correspondent institution’s risk management strategy to reflect these changes.

While correspondent banking is important for the smooth functioning of international trade and transactions, both respondent banks and correspondent banks should have strong AML/CFT compliance programs to mitigate risks. The use of efficient and effective anti-money laundering software is crucial for the success of any AML/CFT compliance program.

The Tookitaki Anti-Money Laundering Suite, an end-to-end, AI-powered AML/CFT solution, is helping financial institutions comply with many regional and international AML compliance regulations and build scalable and sustainable compliance programs that effectively counter AML risk, including correspondent banking AML risk.

To know more about our AML compliance solution and book a demo, please contact us.

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Having transformed many ideas into profitable businesses, crowdfunding, a new-gen investment trend enabled by the internet, has become the first resort for many entrepreneurs and small businesses. The...

The Crackdown on Shell Companies and the Role of Technology

The Anti-Money Laundering Act (AMLA) 2020, enacted as part of the National Defense Authorization Act (NDAA) 2021 of the US in January this year, had many key provisions to take the Anti-Money Launderi...

Tookitaki Powers AI-Driven Anti-Money Laundering Solution Using HPE GreenLake

Hewlett Packard Enterprise (HPE) announced a key collaboration with Tookitaki to provide a new offering designed for banks and financial institutions across Asia-Pacific. The new offering delivers T...

AMLA 2020: 8 Key Provisions that Financial Institutions Required to Know

The US Congress passed the National Defense Authorization Act (NDAA) 2021 on January 1, 2021, addressing a variety of pressing concerns related to the nation’s security. The act included a number of...

The Rising Case for RegTech to Address AML Risks Amid COVID-19

Emerged as a subset of FinTech, the Regulatory Technology (RegTech) industry has now gone more mainstream, thanks to regulators and industry practitioners. Recently, there have been many pro-RegTech c...

Hakrinbank Selects Tookitaki to Ensure Sustainable Financial Compliance Monitoring

Tookitaki announced a partnership with Hakrinbank, a leading South American bank based in Suriname, to fortify its Anti-Money Laundering (AML) detection and alerts management capabilities. To improve...

Breaking Barriers: 5 Key Insights on RegTech Adoption

HKMA in a report shared comprehensive hands-on experience and insights from respondents to better understand the factors and dependencies affecting AML/CFT Regtech adoption. The regulator collaborated...

How to Address Present-day Sanctions Screening Pain Points with AI

Sanctions risk of financial institutions is evolving in line with the global social, economic and political changes. As seen in recent news, governments across the globe are increasingly relying on sa...

Tookitaki Got Selected for FinTech Program: Asia meets Tokyo

Tookitaki has been listed among 8 Fintech startups in Asia for FinTech Program: Asia meets Tokyo, an accelerator launched by the Tokyo Metropolitan Government (TMG). We have been selected for our anti...

AML Alert Management: How AI can Augment Your Compliance Efficiency

The financial sector is facing one monster of a problem at the moment. As today’s financial institutions deal with millions of daily transactions, several thousands of routine financial transactions...

Tookitaki Recognised for Innovative Use of AI & Machine Learning

Tookitaki has won the Regtech Award for AI & Machine Learning and was highly commended in the solutions category for AML/CTF Compliance, in the 3rd Regulation Asia Awards for Excellence 2020 ...

Our UOB Success Tale: Setting a New Benchmark for AI-based AML Compliance

Tookitaki achieved a rare and historic milestone as our Anti-Money Laundering Suite (AMLS) solution went live within the premises of United Overseas Bank (UOB), one of the top 3 banks in Singapore.

Tookitaki Wins 2020 WITSA Digital Innovation Award

Tookitaki has won the 2020 Digital Innovation Award from the World Information Technology and Services Alliance (WITSA) as part of the industry body’s Global ICT Excellence Awards. Nominated by...

Money Laundering via Cryptocurrencies: All You Need to Know

Money laundering via cryptocurrency has been going on for a while now. We’ve all heard of Bitcoin, Ethereum and Dogecoin. Crypto is used by financial criminals globally but how are they getting away...

CNA 938 radio interviews Tookitaki Co-founder Jeeta Badopadhyay

Tookitaki Co-founder and COO Jeeta Bandopadhyay was named among the Singapore 100 Women in Tech (SG100WIT) List in September 2020. A collaboration between the Singapore Computer Society (SCS), IMDA, S...

Need for New Customer Risk Rating Models: Not All Customers Are Created Equal

Being estimated at between US$800 billion to US$2 trillion every year, money laundering is a serious problem for the global economy. While regulators and financial institutions are working hard to pre...

Is AML Compliance Heading for a New Normal in the Age of Digital Payments?

Increased digitization has influenced various businesses and brought in a paradigm shift in the way they create business models and approach growth opportunities. Moving away from conventional transac...

Excel to AI: How Reconciliation Tools Evolve for Better

In the world of finance, reconciliation is the process of comparing two related sets of records or two accounts at the end of a specific accounting period to find out if account balances are matching ...

Lessons Not Well Learned: 2020 AML Fines Cross 2019 Total

If research is to be believed, institutions across the globe have not done enough in the anti-money laundering (AML) compliance area. Data from consultancy Duff & Phelps revealed that AML fines in...

Exploring AML Risks in COVID-Era and the Ways to Address Them

The world continues to battle the COVID-19 pandemic and the crisis it brought in is unprecedented in the history of humankind. While there are a number of pandemic-related factors contributing to the ...

AML Amid COVID-19: Watch out for These FBI-listed Fraud Schemes

There has been a rise in the number of cybercrimes and fraud schemes across the globe ever since the proliferation of the COVID-19 pandemic. Criminals, in general, are taking advantage of people’s s...

OCC Spring Risk Perspective: 5 Takeaways on Compliance Risk

Despite its general strength, the US federal banking system is apparently susceptible to the ongoing economic weakness caused by the rampant spread of coronavirus. Earlier this month, The US Office of...

How Criminals Used COVID-19 Sales Pitch to Defraud, Launder Money

As the world is working hard to contain the spread of the COVID-19, criminals continue to take advantage of the pandemic. They are devising sophisticated methods to defraud people and launder the crim...

5 Top Myths and Facts about AI Implementation in AML Programs

We are more confirmed about the power of Artificial Intelligence (AI) to transform lives and businesses now. There are countless possible applications of AI and machine learning at present, and we see...

Typology Repository Management: Solving AML Problems Via Collective Intelligence and Continuous Learning

Despite its general strength, the US federal banking system is apparently susceptible to the ongoing economic weakness caused by the rampant spread of coronavirus. Earlier this month, The US Office of...

Whitepaper: Automated AML Pattern Detection Using Network Science

Despite its general strength, the US federal banking system is apparently susceptible to the ongoing economic weakness caused by the rampant spread of coronavirus. Earlier this month, The US Office of...

Money Laundering Amid COVID-19: What Regulators Across Globe Say

As the world continues to fight against the COVID-19 pandemic, there are reports that criminals are taking advantage of the difficult situation. They are seizing the moment to proliferate their crimin...

How will Art Cease to Be a Preferred Money Laundering Vehicle?

Money laundering via high-end art and antiquities is not new yet it is difficult to detect. Art-related money laundering amounts to about US$3 billion per year, according to this blog, quoting the Uni...

Beware! Money Mules in Demand amid COVID-19. Here’s an Effective Cure

If reports are to be believed, cybercrooks are taking advantage of the COVID-19 situation. They are targeting people who were laid off or working from home due to the pandemic to work for them as mone...

How do we weather a tornado of change?

“Great works are performed not by strength but by perseverance” – Samuel Johnson All of us are in challenging times. However, we cannot afford to be lethargic to life, work, and busi...

Roundtable Rewind: Embracing Next-gen Tech & Collaboration Key to Sustainability

As a regtech player with a vision to enable sustainable compliance programs in financial institutions, Tookitaki organized a first-of-its-kind industry roundtable in Charlotte, NC, USA to discuss oppo...

Tookitaki Appoints Industry Veteran Joe Friscia as Advisor

Tookitaki Holding Pte. Ltd. appointed industry veteran Joe Friscia, former President of NICE Actimize and BAE Systems as Advisor to the Company’s Advisory Board. Joe brings over 25 years’ extensi...

Should Modern Machines Be Ethical?

There are mounting concerns across the globe about the reliability and safety of artificial intelligence (AI) based systems and its enabling technologies such as machine learning (ML). On the air are ...

Tookitaki Raises Another US$11.7 million in Series A; Closes Round at US$19.2 million

– by Abhishek Chatterjee, Founder & CEO The Tookitaki team and I are excited to announce that we have raised an additional US$11.7 million in Series A funding, taking the total investment in...

30 Years of FATF: Notable Facts About Global AML Watchdog

The Financial Action Task Force (FATF), the intergovernmental body formed in 1989 to combating money laundering, is celebrating its 30th anniversary this year. Since its inception, the global agency p...

Tookitaki Joins Aite Financial Crime Forum as Sponsor

Technological advances have fundamentally changed the operational landscape of financial institutions. However, there are also new risks emerging in forms of sophisticated financial frauds and complex...

Will Machine Learning Replace Compliance Professionals?

The impact of modern technologies such as artificial intelligence (AI) and machine learning on job security has been a widely discussed topic today. Of course, AI has advanced very quickly in the last...

6 Most Prevalent Cyber-Laundering Methods in APAC

Despite being a medium to exchange information in real-time and with scale, the Internet is being misused in several ways. Among the slew of financial crimes facilitated by the Internet, money launder...

What Made Us Earn the WEF Technology Pioneer Title

Tookitaki has bagged another global acknowledgement for its outstanding works in the regulatory compliance field. Our company was selected among hundreds of candidates as one of the World Economic Fo...

We Stay as a Team, We Win as a Team and We Flourish as a Team

“Teamwork is the ability to work together toward a common vision. The ability to direct individual accomplishments toward organizational objectives. It is the fuel that allows common people to a...

ABA Regulatory Compliance Conference: 10 Sessions You Can’t Miss

The 2019 edition of the American Bankers Association (ABA) Regulatory Compliance Conference is a few more days away. Organized by the Washington, D.C.-based trade association, the conference is touted...

Tookitaki AMLS Wins SBR Technology Excellence Award 2019

Tookitaki’s Anti-Money Laundering Suite (AMLS), an end-to-end machine learning-powered transaction monitoring and names screening solution, has bagged the inaugural Singapore Business Review Tec...

Watchdogs Grow Optimistic about AI Prospects at Banks

Proper regulation of banking operations is important as any failure in the banking system would affect the wider economy. Therefore, banking is one of the most regulated industries across the globe. F...

Pitfall of Black Box AI at Banks: Explaining Your Models to Regulators

The use cases of artificial intelligence (AI) and machine learning in front-office, middle-office and back-office activities at banks are growing slowly but steadily. The major areas of AI play includ...

AI for Regulatory Compliance at Banks: 4 Assessments Before You Okay the Solution Proposal

Banking is one of the industries where artificial intelligence and machine learning find their applications at a rapid pace. Regulatory compliance within banking is an area which has become a costly a...

We Believe in Innovation, the Key to Survival and Growth

“Innovation distinguishes between a leader and a follower.” -Steve Jobs What comes on the top of your screen when you google the meaning of the word innovation is – the introduction of somet...

Compliance Functions in Need of a Technological Overhaul. Can Machine Learning be the Game-Changer?

McKinsey in its latest compliance benchmarking survey found that compliance function at financial institutions has reached “an inflection point” and current compliance standards are in an “incho...

Tookitaki Raises US$7.5 mn Series A from Global VCs to Transform Regulatory Compliance

Tookitaki, a regulatory technology company that aims to enable financial institutions to develop sustainable compliance programs, has raised US$7.5 million in Series A round. The round was co-led by L...

The Biggest Money Laundering Cases: From Wachovia to Danske Bank

Money laundering – the criminal activity of processing criminal proceeds to disguise their origin – is one of the gravest problems faced by the global economy, and its size is growing rapidly. It ...

A Modern Approach to Address the Reconciliation Challenges of Financial Services

Reconciliation of transactions is deemed critical for the smooth running of every financial institution. The speed and accuracy of data reconciliation can distinguish a successful institution from its...

Busting a Myth: Compliance Officer’s Job is All About Risk

Regulatory compliance has become a dreadful task for banks after regulators across the globe set stricter norms in the aftermath of the 2008 financial crisis in an effort to prevent financial crimes s...

Attending ACAMS Conference in Singapore? Tookitaki Awaits You with Its Disruptive AML Solution

“In today’s era of volatility, there is no other way but to re-invent. The only sustainable advantage you can have over others is agility, that’s it.”- Jeff Bezos Singapore is hosting ACAMS’...

MAS’ Stress on Transaction Monitoring for Effective AML/CFT Compliance and Machine Learning is the Answer

Singapore is known for its top-notch AML/CFT regime created through up-to-date legislation, stringent policy and uncompromising supervision to safeguard against the abuse of the city state’s financi...

Mifid II and the Pressing Need for a New Reconciliation Approach

The financial services industry in the EU has been confused with the introduction of a revamped version of the Markets in Financial Instruments Directive (Mifid II). The ambitious regulatory reforms t...

Is Automated Reconciliation Next to Impossible in Today’s Complex Financial World?

The 2008 global financial crisis and fairly new regulatory requirements like Basel III asked financial institutions (FIs) to cut operating costs and adopt a lean operations structure, pushing FIs to r...

Modern Tech to Reshape US AML Compliance with Regulators’ Recent Handshake

George Bernard Shaw once said: “Those who cannot change their minds cannot change anything.” The past week has seen a significant change of mind from financial regulators in the US in their ardent...

Skills Development: We Have Talents and We Strive to Multiply Them

“Mastery lies on an infinite continuum, and as a result, we will never reach the end. We can, however, see to it that we are as far along that continuum as our circumstance allows.” ― Chris Mat...

It’s Our Fourth Founding Day; Taking a Pause to Cherish Our Simple but Awesome Journey

Today, as we step into our 4th year of foundation, I feel proud and honored to be leading Tookitaki that has been successful in creating added value to all its stakeholders. I was never a CEO and Took...

Tookitaki Expands into the US with New Office in Charlotte

SINGAPORE, Sept. 24, 2018: Tookitaki Holding Pte Ltd, a leading regulatory technology company, is pleased to announce the official opening of its North American office in Charlotte, NC, in the Unite...

We Tame Machines but We Unleash Human Spirits

We are well aware of the fact that our progress as an organization is in the hands of our employees. The more energy, time and attention we invest in them, the more yield we receive. So, we always mak...

5 Modern Money Laundering Methods That Criminals Use

Modern money launderers are updating their methods to beat detection and avoid getting caught every single day. Where there is new technology, cryptocurrencies and processes, there is a money laundere...

Risk Management Conference: Positive Vibes from All Corners

The Risk Management Association’s (RMA) premier annual event, the Risk Management Conference, came to an end on 6 November, and Tookitaki had the privilege to attend the event which we believe was ...

Singapore Fintech Festival: Tookitaki to showcase advanced machine learning solutions in financial services

Singapore is assured of the Fintech world’s unwavering attention next week, as the city state, is hosting this year’s Fintech Festival during 12-16 November. Touted as the world’s largest platfo...

The RMA Clarion Call to Address Risks and the Tookitaki Way

Risk officers, doing your best today is good while preparing hard for tomorrow is extraordinary. Risk management at banks has become difficult due to operational and regulatory changes. The Risk Manag...