Money Laundering Bulletin
Correspondent accounts
Timon Molloy (timon.molloy@informa.com), Editor

One reason major banks are pruning their correspondent relationships may be that so many are under enforcement actions – deferred
prosecution agreements (DPAs) and consent orders, some stretching back years, perhaps even already extended – their risk appetite
has reduced lest they find themselves in the firing line again, this time (and possibly not the first) for inadvertently handling
criminal proceeds of a customer’s customer. “At some point banks have to get out from under these orders to accept more risk,”
Daniel Stipano, partner at law firm BuckleySandler and former deputy chief counsel at the Office of the Comptroller of the
Currency (OCC), told delegates to the ACAMSmoneylaundering.com 22nd Annual International AML & Financial Crime Conference
in Miami last week [3-5 April].