Anti-Money Laundering and Counter-Terrorist Financing Measures
Correspondent banking relationships are subject to strict anti-money laundering (AML) and counter-terrorist financing (CTF) measures.
Financial institutions must identify and manage the risks associated with these relationships.
Specific due diligence measures are applied when conducting cross-border correspondent banking.
De-Risking and its Impact
In recent years, some financial institutions have chosen to avoid potential money laundering or terrorist financing risks by terminating business relationships with entire regions or customer classes. This practice is known as “de-risking.”
De-risking negatively impacts correspondent banking, leading to financial exclusion, reduced transparency, and increased exposure to illicit activities.
The international community, including the Financial Action Task Force (FATF), considers de-risking a serious concern.
Risk-Based Approach (RBA)
Since June 2015, the FATF has clarified the application of the risk-based approach to correspondent banking relationships.
The financial sector welcomed this clarification but sought further guidance on regulatory expectations, especially regarding customer due diligence.
Guidance on Correspondent Banking Services:
The FATF developed comprehensive guidance to address regulatory expectations in the context of correspondent banking services.
This guidance emphasizes managing, rather than avoiding, money laundering and terrorist financing risks associated with these business relationships.
Collaboration with the private sector and other international bodies ensures effective implementation and adherence to these standards.
KYC/AML requirements
In order for Attica Bank to establish cross-border correspondent relationships with financial institutions based in third countries, the following requirements must be met:
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- Correspondent Banking Due Diligence Questionnaire (CBDDQ)
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- Bank License
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- W8BEN / FATCA Documents
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- Shareholders’ structure/ Ownership Documentation
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- USA PATRIOT Act Certification – for institutions required to provide Certifications
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- Bank’s Representation
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- Extract from commercial register
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- Members of Board of Directors Biographies
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- Declaration of Beneficial Owners
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- Articles or Certificate of Incorporation
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- Articles or Certificate of Association
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- Financial Statements/Annual Report
*The requested documents are adapted and modified on a case – by -case basis, taking into account factors such as the country of residence, the type of correspondent relationship etc.