Thread Options
#1784320 - 02/08/13 07:08 PM Non-Cooperative Countries
Calmeida12 Offline
100 Club
Joined: Sep 2012
Posts: 249
Are we allowed to send/receive wires from Non-Cooperative countries provided on the list from FATF?

Return to Top
BSA/AML/CIP/OFAC Forum
#1784373 - 02/08/13 08:37 PM Re: Non-Cooperative Countries Calmeida12
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Yes. You are required to be aware of your activity with these countries, because presumably their AML controls are not up to standard, but you can conduct business with those countries.

The countries that you may not do business with are the US Sanctioned countries.

Note that some on FATFs list are on the US Sanctioned list.

Return to Top
#1784381 - 02/08/13 08:48 PM Re: Non-Cooperative Countries Calmeida12
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
To ensure appropriate due diligence, you might want to have a process to identify and escalate for review prior to processing these wires. EDD might include documenting purpose of the wire if this is not already part of your process, review of originator's/beneficiary's wire history, etc. Each bank has to determine what "EDD" will mean to them.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top

Moderator:  Andy_Z