Curious how many of you conduct enhanced due diligence in regards to wire transfers to or from countries listed on the FATF list? What level of EDD do you perform? Thanks!

We don't actually conduct an EDD because of the list, but we do ensure that everyone is aware of the countries.
We monitor all foreign wire activity and all customers with extensive foreign wire activity have an EDD performed on their regular rotation based on risk, regardless of which country they are doing business with.
If a country is added we would do a cursory review to see what customers we have doing business with that country.

It was recommended during a recent audit that any wire to or from one of those countries be scrutinized to find out source of funds, purpose of wire, etc and document such.

Recommended by whom?? And to which specific list are you referring too. FATF maintains several lists.

^ Exactly what I was thinking Randy. The countermeasure list is a no fly zone list in my mind. I can't imagine that most US banks want to conduct transactions for Iran and North Korea.

The jurisdictions with AML/CFT deficiencies are not in the same category, but I can see an auditor making the recommendation that PQ detailed. I believe there is about 4 jurisdictions currently listed.

The DD one would conduct on jurisdictions with an action plan would really depend on the bank and their risk appetite.

I think the auditor's recommendation is a little overkill if you already have knowledge of your customer documented.
Do you have a statement in your RA that addresses FATF and how you will handle their listings?

Right now there are only four countries on the list so you can push back or not depending on how much activity you have with these countries.

Algeria
Ecuador
Indonesia
Myanmar

Our BSA auditors (not examiners) provided the Fincen advisory FIN-2014-A006, jurisdictions with AML/CFT deficiencies and made the following recommendation "Management develop and implement procedures, etc, to identify funds transfers from those countries (which we would see during our wire log review anyway) and due diligence should include, at a minimum, identification of the source of the funds (impossible on an incoming wire and the customer must have available funds in an account for an outgoing wire), documentation to support the purpose of the transfer (so on an incoming wire, call our customer prior to posting to ask why they received the wire from Turkey?????) and whether any significant cash activity is involved for a period of time before and after the transfer. An explanation between the beneficiary and originator should be documented as well. I agree overkill on all counts but was curious how others handled this.

In addition, the guidance on jurisdictions subject to EDD is related to maintaining correspondent accounts, I see no suggestions related to wire transfers.

When that advisory came out, we reviewed a list of the wire activity with those countries. We had no activity with two of them, about five a year with another and many with the fourth.
We simply documented on that report that we had EDD on those customers.
We do not review each wire, each month.
Hope that helps.

It does, thanks MC!

You're welcome.