How will the Final Rule affect my banks foreign correspondent relationships?
Your bank will be expected to conduct an appropriate risk-based due diligence when establishing a foreign correspondent relationship. Your bank will NOT be required to conduct due diligence of commercial customers of the foreign correspondent. The Final Rule will only apply to cross-border debits (ACH debits and check collections). If your bank is informed by a U.S. government entity (law enforcement agency or a regulator) that a foreign correspondent has sent your bank a restricted transaction, your bank will be expected to provide notice to that correspondent. A sample model notice is included with the Final Rule. What should my bank do if it suspects or obtains “actual knowledge” an individual customer is using their account to place bets? Transactions conducted by individuals are not subject to the Final Rule. However, nothing in the Final Rule changes your bank’s obligation to file suspicious activity reports if you suspect a customer’s behavior is suspicious. What should my bank
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