Highlights:
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The guidance supplements the June 2004 Guidance on Accepting Accounts from Foreign Governments, Foreign Embassies, and Foreign Political Figures.
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The Agencies recognize that foreign mission accounts involve varying degrees of risk. Financial institutions may reduce risk by ensuring customers are aware of the requirements of U.S. banking laws and regulations, entering into a written agreement with the foreign mission, or offering limited purpose accounts.
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Financial institutions are expected to conduct appropriate risk assessments and implement requisite controls and oversight systems to effectively manage risks associated with the account relationship.
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The Agencies, consistent with their usual practice of risk-based supervision, will evaluate the risks associated with the account relationship and mitigating controls.
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Account monitoring to ensure compliance with established limitations and the terms of any service agreements is essential to mitigate risks.
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The Agencies will not direct or require financial institutions to close or refuse a particular account relationship, except in extraordinary circumstances.
Distribution:
FDIC-Supervised Banks (Commercial and Savings)
Suggested Routing:
Chief Executive Officer
BSA Compliance Officer
Related Topics:
Bank Secrecy Act
Anti-Money Laundering
Counter-Terrorist Financing
Attachment:
Guidance on Accepting Accounts from Foreign Embassies, Consulates, and Missions (Printable – PDF) (PDF Help)
Contact:
Chief, Anti-Money Laundering Section, Debra Novak at SASFIL@FDIC.gov or (202) 898-3673
Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/news/financial/2011/index.html.
To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html.
Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center,
3501 Fairfax Drive, Room E 1002, Arlington, VA 22226 (877-275-3342 or 703-562-2200).
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