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Correspondent Banking Due Diligence Template (FATF R.13, 31 CFR 1010.610)

Correspondent banking file: legal basis, services, respondent profile, ownership and licence, jurisdiction, AML/CFT and sanctions controls, nested and payable-through, shell bank checks, rating, approval, monitoring

ISO & KonformitätVollständigFATF R.13; EU AMLR (EU) 2024/1624 Arts 36, 38, 39 from 2027-07-10; 31 CFR 1010.610 and 1010.630correspondentbankingduediligence

Anleitung: Use it when your bank opens or reviews a correspondent relationship with a respondent outside your jurisdiction. Fill services, respondent profile and jurisdiction first, then test the respondent's questionnaire answers against public sources and your own payment data. The main pitfall is missing nested downstream banks until their names appear in payment messages.

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Correspondent Banking Due Diligence: [Respondent institution]

Due diligence assessment of a cross-border correspondent banking relationship from the correspondent's side: services requested, respondent profile, ownership and licensing, jurisdiction, assessment of the respondent's AML/CFT and sanctions controls, nested relationships and payable-through accounts, shell bank checks, risk rating, documented responsibilities, senior management approval and ongoing monitoring. Based on FATF Recommendation 13 (Correspondent banking, cited by number and title), the current EU framework (Directive (EU) 2015/849 Arts 19 and 24 as transposed in national law), the EU Anti-Money Laundering Regulation, Regulation (EU) 2024/1624 (AMLR) Arts 36, 38 and 39, which apply from 2027-07-10, the UK Money Laundering Regulations 2017 (reg. 34) and US rules 31 CFR 1010.610 (due diligence for correspondent accounts) and 31 CFR 1010.630 (foreign shell bank prohibition and records), as of 2026-10. Replace every [bracketed] value and every row marked Example. This is a document format, not legal, compliance or regulatory advice. Obtain the standard or law for the normative text and check current local law.

Document control

FieldValue
Document ID[CBDD-YYYY-NNN] (Example: CBDD-2026-014)
Respondent legal name[Name] (Example: Mareval Commercial Bank plc)
Respondent country of licence[Country] (Example: [Country A])
Respondent identifiers[LEI], [BIC], [Licence number]
Correspondent booking entities[Entities] (Example: Fernhollow Bank head office (EUR); Fernhollow Bank New York branch (USD))
Relationship status[Prospect / Active / Restricted / Exiting / Closed]
Version[1.0]
Status[Draft / Pending approval / Approved / Declined]
Owner[@fi-relationship-manager]
Approvers/reviewers[@fi-kyc-analyst], [@mlro], [@senior-management-approver]
Risk rating[Low / Medium / High] (see section 10)
Last updatedYYYY-MM-DD
Next review dueYYYY-MM-DD
ClassificationConfidential: financial crime compliance, need-to-know

Approvals

RoleNameDecisionDate
FI KYC analyst (preparer)[@name][Complete]YYYY-MM-DD
Financial crime compliance reviewer[@name][Supports / Does not support]YYYY-MM-DD
MLRO or BSA officer (US branch)[@name][Supports / Does not support]YYYY-MM-DD
Senior management approver[@name][Approve / Approve with conditions / Decline]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
1.0YYYY-MM-DD[@name]Onboarding assessment
1.1YYYY-MM-DD[@name]Example: Added US certification received from respondent
2.0YYYY-MM-DD[@name]Example: Annual review after downstream bank added

Contents

1. Scope and legal basis

A correspondent relationship exists when one institution (the correspondent) provides banking services to another institution (the respondent), such as accounts, payment execution, cash management, foreign exchange or trade services, so that the respondent can serve its own customers. The correspondent usually has no direct relationship with those underlying customers, which is why the law requires extra measures when the respondent is outside the correspondent's own jurisdiction.

JurisdictionRule (as of 2026-10, check local law)Main requirements, in summaryStatus
InternationalFATF Recommendation 13 (Correspondent banking)Understand the respondent's business, reputation and supervision; assess its controls; senior management approval; clear responsibilities; payable-through checks; no shell banksStandard
EU (current)Directive (EU) 2015/849 Art. 19 (cross-border correspondent relationships with third-country respondents) and Art. 24 (shell bank prohibition), via [Member State] lawEnhanced measures for third-country respondentsIn force until 2027-07-09 via national law
EU (from 2027-07-10)AMLR Art. 36 (enhanced measures for cross-border correspondent relationships with third-country respondents), Art. 38 (measures where AMLA issues a recommendation on an individual respondent), Art. 39 (no relationships with shell institutions)Information on business, reputation and supervision; assessment of AML/CFT controls; senior management approval; documented responsibilities; payable-through checks; documented reasons when terminating for AML/CFT reasonsApplies from 2027-07-10 (Art. 90)
UKMoney Laundering Regulations 2017, reg. 34 (correspondent relationships)Enhanced measures for correspondent relationships with third-country respondents; shell bank prohibitionIn force, check amendments
US31 CFR 1010.610 (due diligence programme for correspondent accounts for foreign financial institutions)Risk-based due diligence for all foreign FI correspondent accounts; enhanced due diligence for foreign banks with offshore licences or licences from designated jurisdictionsIn force
US31 CFR 1010.630 (foreign shell banks; records of owners and agents)No accounts for foreign shell banks; reasonable steps against indirect use; owner and agent records; certification safe harbour renewed at least every three yearsIn force

2. Relationship and services requested

Describe the services, currencies, expected volumes and the respondent's reason for choosing this correspondent. Separate services for the respondent's own account (treasury, interbank funding) from services that carry its customers' payments, because the second group brings the respondent's customer risk into your payment flows.

ServiceCurrencyFor respondent's own account or customers?Expected monthly countExpected monthly valueRequested?
Vostro current account (Example)EURBoth3,500EUR 210,000,000Yes
USD clearing via US branch (Example)USDCustomers2,200USD 140,000,000Yes
Trade finance (letters of credit confirmation) (Example)EUR, USDCustomers40EUR 18,000,000 equivalentYes
FX spot and forwards (Example)MultipleOwn account60EUR 35,000,000Yes
Cash (banknote) servicesAnyNo
Payable-through or sub-accounts for customersAnyNo (prohibited by policy)
Downstream (nested) clearing for other banks (Example)USDOther banks' customers300USD 12,000,000Yes, see section 8

Stated purpose: [Summary] Example: Mareval Commercial Bank plc serves importers and exporters in [Country A] trading with the EU and needs EUR and USD clearing with trade finance support. It is replacing a correspondent that withdrew from the region in 2025.

Assess the relationship on its own risk rather than ending it by category. Withdrawing from whole regions or respondent types can push payments into less transparent channels; the risk-based approach expects the correspondent to manage the risk of each respondent where it can, and to record its reasons where it cannot.

3. Respondent profile

Gather enough information to understand the nature of the respondent's business and to determine from public information its reputation and the quality of its supervision. Use annual reports, regulatory disclosures, rating agency reports and press, and confirm material points in a call or visit with the respondent's management and its compliance function.

ItemValue
Business lines[Lines] (Example: Corporate and SME banking 55%, retail 35%, treasury 10% of revenue)
Total assets and market position[Amount, rank] (Example: EUR 9.6 billion equivalent; fourth largest bank in [Country A])
Customer base[Segments] (Example: 1.1 million retail customers; 18,000 corporate customers, mainly agriculture exports and construction materials imports)
Higher-risk customer segments[Segments and share] (Example: Money service businesses 0.4% of deposits; PEP relationships 120)
Geographic footprint[Branches, subsidiaries] (Example: 140 branches in [Country A]; representative office in the EU)
Products of concern[Products] (Example: No bearer instruments; prepaid cards with limits; no virtual asset services)
External auditor[Firm]
Credit rating[Agency and rating, date]
Reputation search[Summary and date] (Example: No AML enforcement in the last five years; a 2024 regional press article on a fraud case at a branch, closed with no regulatory action)

4. Ownership, management and licensing

Identify who owns and controls the respondent, who runs it and who licenses and supervises it. For a listed bank, record the listing and any shareholder above your policy threshold; for a non-listed bank, identify the natural persons or state bodies that own or control it. Where US enhanced due diligence applies, identify each owner of 10 percent or more of any class of securities of a foreign bank whose shares are not publicly traded (31 CFR 1010.610(b)(3)), treating members of the same family as one person.

IDOwnerTypeHolding %Ultimate owner or controllerScreening result
OWN-001 (Example)Mareval Holdings S.A.Holding company62.0Listed on the [Country A] stock exchange; free float 71%Clear
OWN-002 (Example)[Country A] Sovereign Development FundState fund18.0Government of [Country A]Clear; state ownership noted for PEP analysis
OWN-003 (Example)International development finance institutionMultilateral lender9.0Member statesClear
OWN-004 (Example)Free floatPublic11.0DispersedNot applicable

Holdings sum to 62.0 + 18.0 + 9.0 + 11.0 = 100.0 percent.

ItemValue
Banking licence[Type, number, issuer, date] (Example: Full commercial banking licence, central bank of [Country A])
Offshore licence (restricted to non-residents)?[Yes / No] (Example: No)
Prudential and AML supervisor[Authority]
Board and senior management[Chair, CEO, CFO, head of compliance, MLRO; screening results]
PEPs in ownership or management[Names and functions or "none"] (Example: Two board members appointed by the sovereign fund, both senior civil servants)
Physical presence confirmed[Head office address, staff count, evidence]

5. Jurisdiction assessment

Assess the home jurisdiction's AML/CFT regime and supervisory quality and any jurisdiction that shapes the respondent's risk. For a US covered institution, record whether the respondent operates under an offshore banking licence, under a licence from a country designated as non-cooperative by an intergovernmental group in which the United States participates and concurs, or under a licence from a country designated by the Treasury as warranting special measures: any of these requires the enhanced due diligence in 31 CFR 1010.610(b). For an EU correspondent, record whether the country is on the Commission's list of high-risk third countries, which brings additional enhanced measures.

JurisdictionRoleFATF status (date checked)EU high-risk list (date checked)Sanctions regimesUS 1010.610(c) categoryAssessment
[Country A] (Example)Licence and head officeNot on public statements; last mutual evaluation rated [summary] (YYYY-MM-DD)Not listed (YYYY-MM-DD)None country-wideNoneMedium: regional trade with sanctioned neighbour noted
[Country B] (Example)Neighbour with large trade flows[Status][Status]EU and US sectoral sanctionsNot applicableRaises sanctions evasion exposure for trade finance

6. AML/CFT control assessment

Assess whether the respondent's AML/CFT controls are adequate and effective for its risks. The law requires the correspondent to assess the respondent's controls, not to audit them; use proportionate evidence. Score each area, explain the score in a sentence and note the evidence. The areas below are this template's own structure; they are not the order or wording of any industry questionnaire.

IDAreaEvidence reviewedScore (Example scale 1 strong to 3 weak)Comment
CTL-001 (Example)Governance: board oversight, MLRO independence, resourcesBoard minutes extract, organisation chart, interview with MLRO1MLRO reports to the board risk committee; 42 compliance staff
CTL-002 (Example)Business-wide risk assessmentSummary of latest assessment, approval date2Assessment covers trade-based risk but not proliferation financing in detail
CTL-003 (Example)Customer due diligence and EDD, including PEPsPolicy, sample test results from internal audit1Clear EDD triggers; PEP approvals at executive level
CTL-004 (Example)Transaction monitoring and suspicious transaction reportingSystem description, alert volumes, STR statistics2Rules-based system; tuning last performed 2024
CTL-005 (Example)Independent testing and audit findingsInternal audit summary, external auditor letter1No open high findings
CTL-006 (Example)Regulatory findings and enforcementSupervisor's public statements, respondent disclosure22023 supervisory inspection found weaknesses in record keeping, closed in 2025
CTL-007 (Example)Training and staff screeningTraining plan, completion rates197% completion in 2025

Average control score in the example: (1 + 2 + 1 + 2 + 1 + 2 + 1) / 7 = 10 / 7 = 1.43, which the example methodology maps to "adequate with improvement points".

Test the claims against your own data. Example: Fernhollow Bank reviewed three months of the respondent's payments through its previous correspondent (provided by the respondent) and found that 96% of value matched the stated trade corridors and sectors. The remaining 4% were transfers to money service businesses. That share is higher than the 0.4% deposit share stated in section 3, because these customers move funds quickly and hold low balances; the respondent explained the flows and provided its due diligence on the two largest money service business customers, and the gap is recorded as a monitoring point (MON-001).

7. Sanctions control assessment

Assess the respondent's sanctions programme against the regimes that bind your institution (EU, UN, national and, for USD clearing, US OFAC) and the respondent's own regimes. Payments routed through your accounts must not breach the sanctions that apply to you, regardless of the respondent's home law. Link to your own procedure (compliance/sanctions-compliance-procedure) for the controls you apply to the respondent's payments.

AreaFindingAssessment
Lists screened[Lists] (Example: UN, EU, OFAC, UK, local list)[Adequate / Gap]
Screening points[Points] (Example: Onboarding, daily customer rescreening, real-time payment screening, trade documents)
Ownership and control rules[Approach] (Example: Applies 50 percent aggregation for OFAC and EU control tests)
Trade finance controls[Approach] (Example: Vessel and port checks, dual-use goods review)
Payment message transparency[Approach] (Example: Full originator and beneficiary data in ISO 20022 messages; no cover payment stripping)
Violations or voluntary disclosures in last five years[Details or none]
Exposure to sanctioned jurisdictions[Summary] (Example: Customers export to [Country B]; respondent has a written policy prohibiting USD flows involving [Country B] sanctioned sectors)

8. Nested relationships and payable-through accounts

Determine whether the respondent will let other financial institutions use its account with you (nested or downstream correspondent relationships), and whether any account would function as a payable-through account, meaning the respondent's own customers would have direct access to your account. For US accounts subject to enhanced due diligence, the correspondent must find out whether the foreign bank provides correspondent services to other foreign banks that use the account and take reasonable steps to assess those banks, and must obtain information about persons with authority to direct transactions through any payable-through account. Under the AMLR (Art. 36(e)) and current EU law, for payable-through accounts the correspondent must be satisfied that the respondent has performed CDD on customers with direct access and can provide CDD data on request.

IDDownstream institutionCountryServices usedExpected monthly valueRespondent's due diligence on itDecision
NST-001 (Example)Corlan Savings Bank (fictional)[Country A]USD clearingUSD 7,000,000File reviewed, rated mediumAllowed with monitoring
NST-002 (Example)Brisk Microfinance Ltd (fictional)[Country A]USD clearingUSD 3,000,000File reviewed, rated mediumAllowed with monitoring
NST-003 (Example)Tessaly Exchange Bank (fictional)[Country C]USD clearingUSD 2,000,000Licence restricted to non-residentsNot allowed

Downstream values sum to USD 12,000,000 a month, as in section 2; after the decision on NST-003, the permitted nested value is USD 10,000,000 a month.

QuestionAnswer
Payable-through or sub-accounts requested?[Yes / No] (Example: No; prohibited by Fernhollow Bank policy)
Downstream list provided and updated how often?[Frequency] (Example: Quarterly, plus notice before any addition)
Nested activity identifiable in payment messages?[Yes / No, how]

9. Shell bank checks and US records

Confirm that the respondent is not a shell bank and that it does not let shell banks use its accounts. US rules prohibit covered institutions from maintaining a correspondent account for a foreign shell bank, require reasonable steps to ensure the account is not used to serve a shell bank indirectly, and allow an exception only for a regulated affiliate (31 CFR 1010.630(a)(1)(iii)). EU law prohibits correspondent relationships with shell institutions (Directive (EU) 2015/849 Art. 24 via national law; AMLR Art. 39 from 2027-07-10).

For US correspondent accounts, keep records in the United States of the owners of a foreign bank whose shares are not publicly traded and of a US resident agent authorised to accept service of legal process, unless the bank files a Form FR Y-7 with the Federal Reserve that identifies its owners (31 CFR 1010.630(a)(2)). A certification or recertification from the foreign bank, obtained at least every three years, provides a safe harbour; for a new account the certification must be obtained within 30 calendar days of opening or the accounts must be closed within a commercially reasonable time (31 CFR 1010.630(b) and (d)(2)). Keep these records for at least five years after the last correspondent account for that bank is closed (31 CFR 1010.630(e)).

CheckEvidenceDateResult
Physical presence (head office, staff, records, supervisor inspection)[Evidence] (Example: Supervisor's register; site visit report SV-2026-03)YYYY-MM-DD[Confirmed]
Respondent policy prohibits services to shell banks[Policy reference]YYYY-MM-DD
US certification received (new account: within 30 days)[Document reference]YYYY-MM-DD
Certification renewal due (three years)YYYY-MM-DD
US agent for service of process[Name, US street address]YYYY-MM-DD
Owner records or FR Y-7 filer[Records / FR Y-7]YYYY-MM-DD

10. Risk rating

Rate inherent risk by factor, apply the control assessment and record the residual rating. Use the institution's financial institution risk methodology; the weights below are an Example.

FactorWeight (Example)Inherent score 1 to 3 (Example)WeightedReason
Jurisdiction0.3020.60Section 5
Business and customer base0.2020.40Trade-focused, small MSB segment
Ownership and PEP links0.1020.20State fund holding, PEP board members
Services and products0.2020.40USD clearing and trade finance
Nested activity0.2030.60Two downstream banks
Inherent total1.002.20

Residual risk in the example methodology is the inherent score multiplied by a control factor: 0.9 for an average control score up to 1.5, 1.0 up to 2.2 and 1.2 above 2.2. The example has an average control score of 1.43, so residual = 2.20 x 0.9 = 1.98, which falls in the example band Medium (1.80 to 2.39). Because a correspondent relationship with a third-country respondent is an automatic EDD case, enhanced measures apply whatever the residual band.

11. Responsibilities and conditions

Document the AML/CFT responsibilities of each institution, so that both sides know who performs customer due diligence on the underlying customers, who screens what, how requests for information will be answered and how quickly. Record any conditions attached to the approval.

IDResponsibility or conditionPartyReferenceTiming
RSP-001 (Example)CDD and EDD on its own customers whose payments pass through the accountRespondentAccount agreement clause [n]Ongoing
RSP-002 (Example)Real-time sanctions screening of all payments through the accountBothAgreement clause [n]Ongoing
RSP-003 (Example)Reply to requests for information on transactionsRespondentAgreement clause [n]Within 5 business days, 2 for urgent requests
RSP-004 (Example)Notify additions to downstream banks before activity startsRespondentSide letter [ref]30 days before
CND-001 (Example)No payable-through or sub-accountsRespondentAgreement clause [n]Ongoing
CND-002 (Example)Downstream activity capped at USD 10,000,000 a month, NST-003 excludedCorrespondent monitoringThis file, section 8Ongoing
CND-003 (Example)Respondent to share proliferation financing risk assessment updateRespondentApproval letterBy 2027-03-31

12. Senior management approval and decision

Obtain senior management approval before establishing the relationship. The approver must have the full file and must be able to decide independently of the commercial target. When a relationship is ended for AML/CFT reasons, the AMLR (Art. 36, from 2027-07-10) requires the decision to be documented; record the reasons here even under current law.

ItemValue
Decision[Approve / Approve with conditions / Decline / Restrict / Exit] (Example: Approve with conditions RSP-001 to CND-003)
Rationale[Summary] (Example: Established, supervised bank with adequate controls; inherent risk driven by nested activity and regional sanctions exposure, mitigated by caps, exclusion of NST-003 and transaction monitoring)
Approver and role[@name, role]
DateYYYY-MM-DD
Exit reason (if exiting)[Reason documented]

13. Ongoing monitoring, review and exit

Monitor the respondent's activity against the expected profile in section 2, the nested caps in section 8 and the responsibilities in section 11. Under 31 CFR 1010.610(a)(3), the due diligence programme must include periodic review of account activity sufficient to judge whether it remains consistent with the type, purpose and anticipated activity of the account. Review the file at a frequency set by risk and earlier when a trigger occurs. If due diligence cannot be performed, follow your procedure: refuse to open, suspend activity, consider a suspicious activity or transaction report, or close the account (31 CFR 1010.610(d) for US accounts).

IDMonitoring controlMetric or threshold (Example)FrequencyOwner
MON-001 (Example)Volume and value versus profileVariance above 30% by corridor escalatedMonthly[@fi-monitoring]
MON-002 (Example)Nested activity capUSD 10,000,000 a month; any unknown downstream BIC escalatedMonthly[@fi-monitoring]
MON-003 (Example)Request-for-information performance95% answered within 5 business daysQuarterly[@fi-rm]
MON-004 (Example)Adverse media and supervisory actionsDaily screening of respondent and ownersContinuous[@screening]
MON-005 (Example)US certification renewalRenew before three-year dateCalendar[@fi-kyc]
MON-006 (Example)Full file reviewMedium residual with EDD: every 12 monthsAnnual[@fi-kyc]

Early review triggers: change of control or licence, supervisory enforcement, new downstream bank, inclusion of the home country on a high-risk or sanctions list, an AMLA recommendation on the respondent (AMLR Art. 38, from 2027-07-10), a pattern of late or incomplete answers to requests for information, and suspicious activity reports involving the respondent's customers.

IDDateTypeFindingsOutcome
REV-001 (Example)2027-06-30Trigger: request-for-information delays4 of 25 requests answered after 5 business daysWarning letter; MON-003 remediation plan agreed
REV-002 (Example)2027-10-31AnnualActivity within profile; NST-001 merged into respondentMedium confirmed; file updated

14. Glossary and references

TermMeaning in this file
CorrespondentInstitution providing banking services to another institution
RespondentInstitution receiving those services to serve its own customers
Nested (downstream) relationshipUse of the respondent's account by other financial institutions
Payable-through accountAccount through which the respondent's customers can transact directly
Shell bankBank without physical presence in any country (US definition); in EU law, an institution without meaningful mind and management where it is incorporated and not part of a regulated group
Regulated affiliateUnder US rules, a shell bank affiliated with a bank that has a physical presence, and supervised by the banking authority that regulates that affiliated bank
Offshore banking licenceUnder US rules, a licence that bars the bank from banking with citizens of, or in the local currency of, the licensing country
CBDDQWolfsberg Group Correspondent Banking Due Diligence Questionnaire (v1.4 current as of 2026-10), named only

References (obtain current versions):

  • FATF Recommendation 13, Correspondent banking (cited by number and title only).
  • Directive (EU) 2015/849 as amended, Arts 19 and 24, and the [Member State] transposing law.
  • Regulation (EU) 2024/1624 (AMLR), Arts 36, 38 and 39, applies from 2027-07-10, EUR-Lex.
  • UK Money Laundering Regulations 2017 (SI 2017/692), reg. 34.
  • 31 CFR 1010.605 (definitions), 1010.610 (correspondent account due diligence), 1010.630 (foreign shell banks, owner and agent records), eCFR.
  • Wolfsberg Group CBDDQ v1.4 (name and version only; no content used).
  • Related templates: KYC and CDD Customer Profile (compliance/kyc-cdd-profile), EDD Memo (compliance/edd-memo), Sanctions Compliance Procedure (compliance/sanctions-compliance-procedure), Sanctions Exposure Assessment (compliance/sanctions-exposure-assessment), Transaction Monitoring Scenario Specification (compliance/transaction-monitoring-scenario-spec), AML Business Risk Assessment (compliance/aml-business-risk-assessment), ISO 20022 Payments Design (industry/iso20022-payments-design).

Standard and licence note

Based on public law: US federal regulations in 31 CFR Chapter X (US government works); EU legislation from EUR-Lex (Directive (EU) 2015/849 and Regulation (EU) 2024/1624), reused with acknowledgement under Commission Decision 2011/833/EU and summarised in original wording; and the UK Money Laundering Regulations 2017 cited by regulation number. FATF Recommendation 13 is cited by number and title only. The Wolfsberg Group CBDDQ is named for identification only; its questions, section order and guidance are not reproduced or mirrored. This template is not affiliated with or endorsed by FinCEN, the European Commission, AMLA, the FATF or the Wolfsberg Group. All names, institutions and figures in the examples are fictional. This template is original text written for this collection. Check the current official version of each law and your national transposition before use. Template licence: MIT.

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