U.S. regulatory developments often influence correspondent banking relationships beyond national borders. Learn how FATF guidance, OFAC sanctions, and cross-border compliance expectations affect international financial institutions.
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OFAC enforcement activity in 2025 signaled a clear shift in expectations. The focus moved from the outcome of a decision to the process behind it and whether institutions could demonstrate
Foodman CPAs & Advisors For compliance teams managing cross-border relationships, the challenge has shifted from identifying whether a concern exists at the time a decision is made to demonstrating how
Financial institutions operating across jurisdictions often face the challenge of applying multiple regulatory frameworks to the same relationship. As sanctions, PEP requirements, and correspondent banking expectations converge, maintaining consistency in decision-making becomes increasingly complex.
Foodman CPAs & Advisors
The expansion of politically exposed person (PEP) categories under the EU AML framework is already defined in the AML Regulation. Recent developments have not introduced new categories. They have clarified
Stanley I. Foodman
Stanley I. Foodman
