Last year, in September, I discussed the increasing trend for some banks to terminate their banking account relationships with banks in certain areas of the world. Kathleen A. Scott, “Work Continues on Addressing Correspondent Banking Decline,” New York Law Journal, Sept. 16, 2016. In this month's column, I highlight some of the recent efforts by international organizations to attempt to address this trend, which unfortunately continues today.

A Little Background

As explained in my September 2016 column, funds transfer around the globe by use of accounts banks maintain with each other—most of them maintained by banks (respondents) at large international banks (correspondents), primarily in the United States, Canada, Europe and the United Kingdom. If the correspondent banks see a higher risk in maintaining those accounts and decide to close them, respondent banks have increasing difficulty accessing the international financial system, which can to consequences such as curtailing international business transactions and impeding the ability for residents of these countries to receive remittances from relatives working abroad.

The Financial Stability Board (FSB) a group of international banking regulators, has been working on this issue and established the Correspondent Banking Coordination Group (CBCG). This organization has been submitting periodic reports to the G-20, the group of international finance ministers and central bank governors. Its latest report was submitted to the G-20 at its July meeting in Germany. Financial Stability Board, “FSB action plan to assess and address the decline in correspondent banking,” July 4, 2017.

In addition, the Financial Action Task Force (FATF), the international organization developing anti-money laundering standards, issued guidance on Correspondent Banking Services issued shortly after last year's column appeared, and the Basel Committee of the Bank for International Settlements issued revisions in June to its correspondent banking guidance contained in its anti-money laundering guidelines. Financial Action Task Force, “Correspondent Banking Services,” Oct. 21, 2016; Basel Committee on Banking Supervision, “Sound management of risks related to money laundering and financing of terrorism,” June 2017.