Foreign Correspondent Account Record Keeping Requirements

B

As per the USA PATRIOT Act record-keeping requirements for United States financial institutions with foreign correspondent accounts, the following information must be retained:

A. Records identifying the owners of each foreign bank: Financial institutions must maintain records that identify the owners of each foreign bank with which they have a correspondent relationship. This information is crucial for identifying and verifying the entities involved in financial transactions and ensuring compliance with anti-money laundering (AML) regulations.

B. Section 314(b) information sharing results related to foreign correspondent accounts: Section 314(b) of the USA PATRIOT Act allows financial institutions to share information with one another in order to identify and report potential money laundering or terrorist financing activities. Financial institutions must retain the results of information sharing related to their foreign correspondent accounts. This includes any information received or provided through the Section 314(b) information sharing process.

C. Purchase of monetary instruments of $3,000 or more involving foreign correspondent accounts: Financial institutions are required to maintain records of any purchase of monetary instruments involving foreign correspondent accounts where the value of the instruments is $3,000 or more. This includes records of the transaction, the individuals or entities involved, and any other relevant details. Retaining these records helps monitor and detect potential money laundering or illicit financial activities.

D. A suspicious activity report filed and the supporting documentation involving foreign correspondent accounts: Financial institutions must retain any suspicious activity reports (SARs) filed in connection with foreign correspondent accounts, as well as the supporting documentation related to those reports. SARs are filed when there is a reasonable suspicion that a transaction or activity involves money laundering or other illegal activities. By retaining the SARs and supporting documentation, financial institutions can provide evidence of their compliance efforts and facilitate investigations if necessary.

In summary, to comply with the USA PATRIOT Act record-keeping requirements for foreign correspondent accounts, United States financial institutions must retain records identifying the owners of each foreign bank, information sharing results under Section 314(b), records of purchases of monetary instruments over $3,000, and any filed suspicious activity reports along with their supporting documentation.