In response to the “derisking” trend in anti-money laundering and Bank Secrecy Act compliance, the OCC will soon issue guidance that articulates its expectations for banks to routinely evaluate risk in their foreign correspondent banking portfolios, Comptroller of the Currency Thomas Curry said today.
Speaking to the Association of Certified Anti-Money Laundering Specialists in Las Vegas, Curry said the guidance will “reiterate our risk management expectations for banks to establish and follow policies and procedures for regularly conducting risk evaluations of their foreign correspondent portfolios.”
The guidance will include “best practices” that OCC examiners have observed, Curry said, including risk governance for foreign correspondent accounts, communications to senior management and consideration banks might give to “any adverse impact that closures may have on access to financial services for an entire group of customers or an entire region.”
Other best practices include communicating with customers while determining whether to end a relationship, giving sufficient time for customers to establish new accounts before termination and maintaining clear audit trails documenting the reasons for the account termination, he added.
