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Correspondent Banking AML Course

Overview
Today more than ever before, the risks posed by correspondent banking are of concern to regulators and bankers and broker-dealers in securities alike.  Various sections of the USA Patriot Act were passed to protect access to the U.S. financial system by obligating U.S. financial institutions to implement additional controls in the area of correspondent banking.  A review of recent enforcement actions imposed on U.S. and foreign financial institutions operating in the U.S. often cite deficiencies in the area of correspondent banking.  While these actions are in response to a particular set of circumstances, there are some general lessons that may be gleaned from reviewing them.  Following the successful completion of testing, each participant will receive a certificate of course completion.

Who Should Attend?
This course is targeted to Compliance, relationship officers, back-office operations personnel, internal audit staff and regulators that examine correspondent banking/account relationships.  Participants should be working in the banking industry or other closely related professions.

Highlights
This advanced level course facilitates the understanding of the following topics related to foreign correspondent account relationships:

  • A review of the circumstances leading up to passage of the USA Patriot Act - The Senate Subcommittee report on Correspondent Banking
  • Key Provisions of the USA Patriot Act that address correspondent banking
  • Other international initiatives that address Correspondent Banking such as FATF and Basle
  • Industry Best Practices – The Wolfsberg Group and The Clearing House
  • Foreign Correspondent Accounts and High Risk Products
  • U.S. Dollar Drafts
  • Pouch/Cash Letter Activities
  • Funds Transfers & Electronic Banking
  • Trade Finance Activities
  • Correspondent Accounts for High Risk Non-Bank Financial Institutions such as MSB
  • Basic Due Diligence Practices for Correspondent Accounts
  • Enhanced Due Diligence for Correspondent Accounts
  • Transaction Monitoring Considerations
  • Shell Bank and Offshore Banking Considerations
  • Funds Transfer Recordkeeping and Transparency (e.g. cover payments)
  • Enforcement Actions that address correspondent banking shortfalls
  • Select case studies

Advanced Preparation
Attendees are expected to complete a comprehensive pre-class reading list that will supplement the successful passing of the exam following the course.  Reading lists include the most recent version of the FFIEC manual, FinCEN and FATF documents, and additional information regarding regulations, etc.
Suggested reading time: 10-15 hours

Course Exam
Participants will be required to successfully complete a short exam immediately following the course.

Course Duration:     One day

Fee:     Members $595    Non-Members $795
 

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