Would anyone be able to share what kind of due diligence do you do for a foreign correspondent bank prior to establishing the relationship? I was thinking of asking them for their BSA Policy, Annual Risk Assessment if they complete one, latest examination and latest audit and then I would complete a risk assessment of that prospect relationship. Also, does anyone have a policy and procedures in place that they would like to share with this regard? We don't bank foreign correspondent banks but might be something that we'll do in the near future and want to be prepared for it. Any help will be greatly appreciated. Thank you.

Questionaire supplied with no warranty as to fitness for a particular purpose. Review the specific section of the FFIEC BSA/AML Examination Manual too. My memory is that it dictates some specific elements of due diligence.

In addition to the Wolfsberg Group Questionnaire linked by Ken, Section 312 of the USA Patriot Act details some very specific requirements you must follow. Depending on the FFI, you may need to get a PATRIOT Act Certification completed.

You're well within your rights to request their AML policies/procedures and their latest examination and internal audit. I would also suggest a list of their high risk customers and why they are high risk, a list of jurisdictions they do business with and stipulations in your contract the PTA's and Nested Accounts are prohibited.

ACBbank - do you mind sharing your Patriot Act certification document? Feel free to PM with your contact info, if you prefer to respond in that manner.

THANKS!

if your google

"patriot act certification form"

There are a lot of forms of many different banks listed but it is the same form for each.

Ed nailed it Ann. It's the basic form, with our name and logo on it.

Thanks edAudit & ACBbank!