Regulatory Alerts2008-01-30
Added
Application of Correspondent Account Rules to the Presentation of Negotiable Instruments Received by a Covered Financial Institution for Payment
FinCEN clarifies that the transaction-by-transaction presentation of a negotiable instrument by a covered financial institution to a foreign paying institution does not establish a correspondent account. Consequently, covered financial institutions are not subject to the due diligence provisions of the correspondent account rule for such presentations, whether made directly or through a clearing facility. This interpretation applies regardless of the volume or frequency of instrument presentations, as these actions do not constitute a formal banking relationship.
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