I am not sure if this is the appropriate forum for this issue so feel free to move it if necessary.
We are a wholly owned community bank that is a subsidiary of a foreign bank. The current interest rate and exchange rate situation in our parent bank's country has resulted in a large number of requests from immigrants living in the US who want to open accounts in their home country and we have been facilitating this activity by means of having the customer complete the account opening documents for the paretn bank and then forwarding the documents to them. We have also required that the customers open accounts with us so we perform CIP, CDD, etc.
Is what we are doing in violation of anything here in the US? For example, could it be construed that the parent bank is accepting deposits in the US without a license?
Any thoughts on this matter will be appreciated.

Bump

Now that the holidays are over and everyone is back at work I wonder if anyone has any thoughts on this matter. Thanks.