FSB全球金融稳定委员会-FSB-action-plan-to-assess-and-address-the-decline-in-correspondent-banking_-Progress-report_21页_558kb

FSB Action Plan to Assess and Address the Decline in Correspondent Banking

Executive Summary

The decline in correspondent banking relationships globally remains a concern, as it may affect the ability to send and receive international payments, potentially driving some flows underground. While no direct impact on the stability of the global financial system has been identified, national and regional concerns persist. The FSB launched a four-point action plan in 2015 to address this issue, coordinated by the Correspondent Banking Coordination Group (CBCG). This is the sixth progress report under the initiative, highlighting ongoing efforts and challenges.

Core Content of the Action Plan

The FSB action plan focuses on four key areas:

1. Data Collection and Analysis
2. Clarifying Regulatory Expectations
3. Domestic Capacity Building
4. Strengthening Due Diligence Tools

1. Data Collection and Analysis

• CPMI Data Report (2019): CPMI published a report analyzing SWIFT data up to the end of 2018, showing continued declines in correspondent banking relationships.
• Key Statistics:
  • Active correspondent banks decreased by 3.4% in 2018, a slower rate than in 2017 (-4.1%) and 2016 (-3.9%).
  • The decline was most pronounced for USD (-5.9%), followed by EUR (-4.6%) and GBP (-3%).
  • 20 out of 22 regions experienced a decline in 2018, with Polynesia and Micronesia being exceptions.
  • Melanesia (-42.9%) and Polynesia (-36.5%) have the largest cumulative declines since 2011.
  • Very small economies (GDP < USD 10 billion) had a smaller decline in 2018 (-2.2%) compared to the global average, but remain the most affected cumulatively (-25.1%).
  • The number of "corridors" (direct connections) declined by 1.9% in 2018, continuing a trend of decreasing direct links.
  • SWIFT message volumes increased by 4.6% in 2018, suggesting a possible extension of payment chains, though this is not confirmed by data.
  • The Gini coefficient for concentration of correspondents increased slightly to 0.75 in 2018.

2. Clarifying Regulatory Expectations

• The FSB and CBCG have worked to clarify regulatory expectations, particularly through FATF and BCBS guidance.
• Nested or downstream correspondent banking arrangements were clarified as legitimate, provided due diligence is adequate to mitigate money laundering and terrorist financing (ML/FT) risks.
• BCBS updated its Annex on correspondent banking, suggesting respondent banks may need more than one correspondent account to manage risks.
• BAFT's "Respondent's Playbook" (2019) outlines best practices for maintaining correspondent banking relationships, emphasizing the need for multiple relationships to reduce rejection risks.
• FATF and BCBS have provided clarity on transaction party identification and due diligence on non-customers (e.g., in trade finance).
• ADB organized a workshop in March 2019 to address regulatory challenges and promote clarity, with discussions on improving examiners' understanding of complex transactions.

3. Domestic Capacity Building

• Capacity building is critical in jurisdictions affected by the decline, particularly those with weaknesses in AML/CFT frameworks.
• The CBCG has coordinated workshops and provided technical assistance to both public and private sectors.
• Key Initiatives:
  • Enhanced coordination of capacity-building activities.
  • Development of national AML/CFT guidance.
  • Encouragement of private sector training and assistance, including the Wolfsberg Group's DDQ and related guidance.
  • Emphasis on consistency across TA providers to improve effectiveness.
  • FATF-Style Regional Bodies are encouraged to play a larger role in TA coordination.

4. Strengthening Due Diligence Tools

• The Wolfsberg Group's DDQ is being implemented across the industry, with tutorials and guidance to ensure proper use.
• Legal Entity Identifier (LEI) is expected to be used in payment messages by 2021, though steps to reduce costs and administrative burdens remain necessary.
• CPMI continues to monitor the implementation of these tools and the effectiveness of information sharing practices.
• Improvements in data sharing and structured reporting (e.g., suspicious activity reports) are encouraged to enhance transparency and reduce risks.

Monitoring and Implementation

• FSB Monitoring Report (May 2019): Shows progress in implementing recommendations, with many jurisdictions adopting good practices.
• Positive developments:
  • Improved regulatory frameworks and coordination.
  • Adoption of innovative technologies.
  • Increased technical assistance.
• Remaining challenges:
  • Continued need for guidance and clarity.
  • Implementation gaps in some regions.
  • Cost and efficiency concerns related to new tools like LEI.

Conclusion

The FSB action plan is making progress in addressing the decline in correspondent banking, but challenges remain in ensuring consistent regulatory expectations, effective capacity building, and the full implementation of due diligence tools. Continued collaboration between public and private sectors, along with technical and policy improvements, is essential to stabilize and strengthen the correspondent banking system.