We are a community bank providing retail services that is wholly owned by a bank in Korea. Currently we provide wire transfer and trade finance services to our parent and they utilize other US banks for other services including cash letter. They have asked us if they can move the cash letter service to us using RDC. The RDC would be done by our parent and not by their individual customers. We do offer RDC to local business customers after risk assessment and we monitor the activity by having the branch of account review the daily RDC activity in their customers' accounts and also we in BSA review each RDC account on an annual basis. I personally don't think we are in a position to monitor and review the RDC activity that would be coming in from our parent since we would not be able to detect 3rd party checks, we would not know anything about their customers who deposited the checks, etc and I am trying to put together an argument against offering RDC under these circumstances and would appreciate any other advice that you all could provide.

You might want to read this:

Citibank C&D Order

Citibank is not the only one. There have been others.