The Office of the Comptroller of the Currency (OCC) on Wednesday issued risk management guidance on reevaluations of risks associated with foreign correspondent banking accounts.to national banks, federal savings associations and federal branches.
As part of their guidance, OCC said banks will assess all risks as part of their ongoing risk management practices.
The guidance focused on a range of best practices for banks to consider when conducting periodic reevaluations on account retention and termination. Best practices in this area include communicating decisions to bank senior management when examining potential international financial inclusion impacts. Other recommendations include considering mitigating information obtained from foreign financial institutions and ensuring a clear audit trail of the reasons and method used for account closure.
OCC said banks should continue to apply the mandatory requirements of the Bank Secrecy Act and Anti-Money Laundering laws when analyzing management risks. Further, banks should certify that any decision to terminate foreign correspondent account relationships be based on analysis of the risks presented by individual foreign correspondent account relationships.
In addition to the guidance issued, the OCC did not direct banks to open, close or maintain individual accounts, nor did it encourage banks to engage in the termination of entire categories of customer accounts without regard to the associated risks.