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#2116920 - 02/03/17 04:17 PM FX Wires To/From Burma - Permitted?
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In October 2016, Treasury terminated the Burma Sanctions Program. In 2003, FinCEN found Burma to be a “jurisdiction of primary money laundering concern” under Section 311 of the USA PATRIOT Act. As a result, FinCEN issued a prohibition on U.S. financial institutions from maintaining correspondent accounts for Burmese banks. The 2003 finding remains in place, but FinCEN issued an administrative exception to suspend the prohibition so that U.S. financial institutions can continue to provide correspondent services to Burmese banks, subject to the appropriate due diligence requirements. FinCEN intends to rescind its action in its entirety when Burma has made sufficient progress in addressing these issues.

Our FI does not maintain foreign correspondent bank accounts. A business prospect (law firm) is seeking to send and receive foreign exchange wires to/from Burma. Is this currently permitted given these regulatory changes? If permitted, does this activity still fall outside of the risk appetite for most FIs?

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#2116924 - 02/03/17 04:38 PM Re: FX Wires To/From Burma - Permitted? BSA Aficionada
Elwood P. Dowd Offline
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Quote:
If permitted, does this activity still fall outside of the risk appetite for most FIs?


Did you solicit the law firm or are they coming to you? If the latter, why?

How much do you charge for international wire transfers? Will they pay the same fee?

Where does this fit in compared with the rest of your wire transfer activity?

If you initiate a wire to Burma, will your intermediary bank accept it?
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#2116927 - 02/03/17 04:50 PM Re: FX Wires To/From Burma - Permitted? Elwood P. Dowd
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This falls way out of our risk appetite and we will not consider onboarding the relationship. With that being said, I wanted to know if these wires are even permitted.

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#2116932 - 02/03/17 05:08 PM Re: FX Wires To/From Burma - Permitted? BSA Aficionada
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Does your bank have the ability to vet the beneficiaries/originators of these wires?

A business prospect (law firm) is seeking

He is a prospect since no one else is willing to take him on as a client,
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#2116934 - 02/03/17 05:13 PM Re: FX Wires To/From Burma - Permitted? BSA Aficionada
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