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MON31 - Smart Strategies to Manage Correspondent Banking Risks

‐ Sep 23, 2019 4:00pm

• Reviewing Patriot Act’s Section 312 to develop due diligence programs that are appropriate, specific, risk-based and designed to detect proceeds of foreign corruption

• Customizing assessments to reflect unique respondent bank risks such as domicile and business profile to ensure controls support correspondent bank risk appetite standards

• Delineating compliance and business side incentives to harmonize oversight in areas such as staff training, alert governance and conflict resolution involving respondent accounts



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