Hoping someone has some insight to the following issue. If a U.S. bank's only relationship with a foreign bank is to occasionally confirm letters of credit issued by the foreign bank, would you consider that relationship a "correspondent account" for purposes of Sections 313 and 319 of the USA PATRIOT Act (or even Section 312), and thereby require Certifications from these foreign banks?

We have taken a very conservative approach, given the broad definition of 'correspondent accounts' that is provided in BSA. Because a confirmed letter of credit would cause our institution to assume the credit obligation of the issuing bank, it could be considered an extension of credit to the issuing bank: Therefore, we believe it could meet the BSA definition if done frequently enough as to constitute a regular relationship with the issuing bank.