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Wire Transfer/International Correspondent Banking -Money launderers have become more creative in their use of wire transfer systems, particularly relating to correspondent bank accounts. Correspondent accounts are accounts banks maintain with each other to facilitate transactions for themselves and their customers. Although these accounts were developed and are used primarily for legitimate purposes, international correspondent bank accounts may pose increased risk of illicit activities. The Minority Staff of the U.S. Senate Permanent Subcommittee on Investigations issued a report on February 5, 2001, entitled “Correspondent Banking and Money Laundering.” The report summarizes a year-long investigation into correspondent banking and its use as a tool for laundering money. The investigation found that U.S. banks through international correspondent accounts could become conduits for dirty money flowing into the American financial system.  

Bankers must exercise due diligence in determining risks associated with each of their foreign correspondent accounts. Factors to consider include account purpose, location of the foreign bank, nature of the banking license, the correspondent’s money laundering detection and prevention controls, and the extent of bank regulation and supervision in the foreign country. The USA PATRIOT Act also requires the maintenance of certain records for foreign correspondent accounts, mandates enhanced due diligence for select accounts, and precludes maintaining correspondent accounts for “shell” banks.  

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