While certainly not a new issue, the identification of correspondent banking as a heightened anti-money laundering (AML) risk factor has recently been partially addressed by the Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ).

The CBDDQ addresses correspondent risk by addressing the following correspondent controls:

  • ENTITY & OWNERSHIP
  • PRODUCTS & SERVICES
  • AML & SANCTIONS PROGRAMMES
  • ANTI-BRIBERY & CORRUPTION PROGRAM
  • POLICIES & PROCEDURES
  • AML & SANCTIONS RISK ASSESSMENTS
  • KYC, CDD & EDD
  • MONITORING & REPORTING
  • PAYMENT TRANSPARENCY
  • SANCTIONS
  • TRAINING & EDUCATION
  • COMPLIANCE TESTING & QUALITY ASSURANCE

One of the keys to successfully mitigating correspondent risk is the synchronization of the above controls throughout operations, and ensuring that accurate, timely information flows through business units and compliance functions.

To learn more about applying effective, efficient operations to improve your compliance program, reach out to our Financial Crimes & Investigations team:

  • Mike Carter, mcarter@alvarezandmarsal.com
  • Larry Iwanski, liwanski@alvarezandmarsal.com
  • Hal Crawford, hcrawford@alvarezandmarsal.com