United States: OCC Provides Guidance On Periodic Risk Evaluation Of Foreign Correspondent Accounts

Last Updated: October 14 2016
Article by Cadwalader, Wickersham & Taft LLP

The Office of the Comptroller of the Currency (the "OCC") issued guidance on best practices for OCC-supervised banks to use when conducting periodic risk evaluations of foreign correspondent accounts and when deciding whether to terminate such accounts.

Foreign correspondent accounts are established by an OCC-supervised bank in order for a foreign financial institution to receive deposits from, to make payments or other disbursements on behalf of, or to handle other financial transactions. The OCC guidance reminded banks that they should periodically evaluate the risks associated with these relationships including compliance with anti-money laundering laws and Bank Secrecy Act laws. Additionally, the OCC outlined supervisory expectations with respect to the evaluations.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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Arnold & Porter Kaye Scholer LLP
Kramer Levin Naftalis & Frankel LLP
Cadwalader, Wickersham & Taft LLP
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