The bank uses two third parties for processing wires. The third-party wire software will block wires to an OFAC blocked country. However, there are a lot of high-risk countries that are not necessarily blocked by OFAC because of different types of sanctions, etc. If you google high-risk countries or BSA AML high-risk countries you will get different answers but some have some of the same countries. I am curious as to other's thoughts about conducting wires for customers to any country that might show up on any list. Does anyone have policies or procedures regarding international wire activity?

Well, if you have customers doing transactions in high-risk countries, then I would think that would qualify the customer as high risk themselves and either you can gather enough due diligence information to determine that the transaction(s) is/are legitimate, or they are no longer a customer.

The closest thing to a universally accepted high risk country list is the FAFT jurisdiction ratings, and I would opine that the FATF's ME's are only one part of analyzing a jurisdiction's risk.

Our current no fly list is the new Axis of Evil (Iran, North Korea, Sudan, and Syria). We will not process any transactions for those countries period. We recently added Russia to this list due to current events.

Outside of those jurisdictions, we will process wires to high risk countries if the purpose of the transaction(s) makes sense and lines up with the story provided by the client.