We are a $2.3 billion bank and currently have only a couple of relationships involving foreign entities. Executive management continues to pursue other large relationships with foreign ties; i.e., parent company is non US with physical locations in our state and registered to do business in our state. I'm looking for a generic EDD checklist to be used for these types of situations to aid the executives in the types of questions they should be having with their perspective clients around BSA compliance risks. If anyone has one they are willing to share I would appreciate it......I hate reinventing the wheel when it's not necessary.

For the record I'm not saying that I agree with their decision.....I just work here.

Smart thing to say; you just eliminated 3/4 of your likely responses.

See if you have an upstream correspondent who can help you out. Otherwise you are running the Laurentian Abyss without a chart.

Thanks Ken!