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Correspondent Banking (CB) can be a risky business. There have been a number of fines related to inadequate CB controls and on June 23, 2022 the UK’s Financial Conduct Authority (FCA) issued another one. With criminals exploiting CB networks and the cost of CB compliance rising, it is no wonder that the number of CB relationships are in decline. This is a problem: CB provides essential infrastructure for growth, financial inclusion, and international trade in smaller economies near and far. Some smaller banks are re-considering the risks and rewards of CB, which can reduce competition.
To manage CB risk effectively, correspondents have taken on the nearly impossible task of becoming mini-regulators, ensuring that respondents operate as they claim on an ongoing basis—this involves a cocktail of desk-based reviews and, depending on the risk, site visits and interviews. At times, correspondents identify gaps in the respondent’s framework, ineffective systems, and lack of resources and poor governance. This is not unusual, given how the anti-money laundering regime and supervision thereof differs globally. Much like a regulatory visit, correspondents provide recommendations to improve the framework and must check that implementation occurs on a timely basis, and that the respondents never go back to ineffective systems and controls once the review is complete. The amount of time, effort, and subject matter knowledge required should not be underestimated.
If your firm is still collecting “paperwork” night and day to satisfy know-your-customer requirements, without having experienced people assessing the contents of the documentation provided, you may well have a problem. There are many examples where respondent banks have told the correspondent what they wanted to hear to secure a CB relationship—but these respondent banks, often interested only in the money, are not running compliance functions as stated. Experience tells us that we should trust but verify.
And finally, for those caught by the Senior Managers Regime, you are the top gun and the buck stops with you. Ensure you have adequate oversight that CB risks are being managed effectively within the firm. Boards should ensure the risk appetite is sufficiently granular to include CB.
Guidehouse Financial Services is expert in reviewing, designing, and enhancing CB frameworks.
Guidehouse is a global consultancy providing advisory, digital, and managed services to the commercial and public sectors. Purpose-built to serve the national security, financial services, healthcare, energy, and infrastructure industries, the firm collaborates with leaders to outwit complexity and achieve transformational changes that meaningfully shape the future.