2018年-世界发展银行全球_The_Decline_in_Access_to_Correspondent_Banking_Services_in_Emerging_Markets___Trends_Impacts_and_Solutions_56页_1mb

The Decline in Access to Correspondent Banking Services in Emerging Markets: Trends, Impacts, and Solutions

Core Content

This report, based on eight country case studies conducted between April and November 2017, examines the decline in correspondent banking relationships (CBRs) in emerging markets, focusing on the causes, impacts, and potential solutions. The study highlights the growing trend of global banks terminating or restricting CBRs, which are vital for cross-border financial transactions and the stability of local economies.

Main Outcomes of the Country Case Studies

3.1 Termination or Restriction of CBRs in the Banking Sector

• General Trends: All surveyed countries reported cases of CBR terminations or restrictions.
• Variation in Impact: Some banks lost many CBRs, while others managed to maintain or even expand their networks.
• Examples:
  • One country saw 9 of 42 correspondents terminate or reduce services to 10 domestic respondent banks.
  • In another country, 35 CBRs were closed between 2015 and 2017, but 10 new ones were established.
  • One bank lost 25 CBRs but reopened 27 new accounts.
  • In a third country, about 158 nostro and MTO-related accounts were closed over four years, but 52 new relationships were formed.

3.2 Termination or Restriction of Accounts in the Remittances Market

• Impact on MTOs: Many money transfer operators (MTOs) faced account closures, disrupting their operations.
• Consequences:
  • Some MTOs resorted to unconventional methods like using personal bank accounts or commercial couriers to move funds.
  • The decline in access to correspondent banking has affected the cost and volume of remittances in different ways.

3.3 Impact on Customers, Products, and Services

• Customer Loss: Banks lost significant numbers of corporate and export-oriented customers.
• Service Disruption: There was a notable drop in remittance volumes and a loss of profitable services, such as USD supply.
• Rating Effects: Derisking negatively impacted some banks' ratings.

3.4 Cross-Border Effects of Derisking

• Regional Spillovers: Derisking had cross-border effects, particularly in the Southern African Development Community.
• Pan-African Banks: Pressured to stop certain activities to maintain CBRs, leading to the termination of USD clearing in several countries.

3.5 Other Potential Implications

• Informal Channels: There is concern that derisking has led to the resurgence of informal financial channels.
• Systemic Risks: The concentration of MTOs and remittance flows in a few banks raises systemic risk concerns.
• Counterparty Risks: Increased concentration of CBRs among fewer institutions has led to higher counterparty risks.

Possible Solutions and Good Practices

4.1 Role of the Public Sector

• Regulatory Oversight: Authorities should improve the regulatory oversight of MTOs and ensure that AML/CFT regimes are effective and proportionate.
• Data Collection: Governments and regulators should collect and share data on CBR closures and their impacts.
• Policy Coordination: Coordination between public and private stakeholders is essential to address derisking effectively.

4.2 Role of the Private Sector

• Contingency Planning: At-risk banks should integrate derisking into their contingency planning.
• Risk-Based Approach: Banks should adopt a risk-based approach (RBA) to manage correspondent banking relationships more effectively.

4.3 Potential of Fintech

• Compliance Costs: Fintech has the potential to reduce compliance costs and improve transaction monitoring.
• Alternative Solutions: Fintech can provide innovative solutions such as e-KYC (Know Your Customer) and digital settlement flows.
• Collaboration: Collaboration with Fintech actors is encouraged to develop more sustainable and efficient alternatives to traditional correspondent banking.

Key Findings

• Macro vs. Micro Impact: While macroeconomic effects of derisking appear limited, micro-level impacts are significant.
• Cost Increases: Compliance costs have risen, making CBRs less financially attractive, and some banks have seen transaction costs increase from USD 9 to USD 50-60.
• Currency Dependence: The loss of USD clearing in some countries has had a direct impact on local economies.
• Informality Rise: There is evidence that derisking has led to a rise in informal financial channels, which could undermine AML/CFT objectives.

Conclusion

Derisking, while sometimes justified due to compliance and risk concerns, has created significant challenges for banks, MTOs, and local economies in emerging markets. The report underscores the need for better data collection, improved regulatory frameworks, and the potential of Fintech to provide sustainable solutions. It also calls for continued research and policy dialogue to better understand and address the long-term implications of derisking.

Critical Information

• Countries Covered: Eight emerging market economies in EAP, LAC, SA, and SSA.
• Confidentiality: Country names were anonymized due to confidentiality restrictions.
• Data Sources: Questionnaires, onsite visits, and secondary data from the World Bank, IMF, and FSB.
• Cost Absorption: Banks and MTOs typically absorb the costs of AML/CFT compliance rather than passing them on to customers.
• Sustainability Concerns: Unconventional methods used by MTOs to bypass CBR restrictions are not sustainable in the long term.

References

• The study builds on previous work by the CPMI, IMF, and IFC, and complements the ongoing efforts by the FSB to address the decline in correspondent banking.
• It also emphasizes the importance of international collaboration and the need for a coordinated response to the challenges posed by derisking.

Box Highlights

• Box 1: Derisking can significantly affect a bank's ratings.
• Box 2: Somalia improved its AML/CFT regime, reducing the impact of derisking.
• Box 3: India implemented e-KYC, which helped reduce the burden of due diligence.
• Box 4: Mexico introduced RYC utilities to facilitate remittances.
• Box 5: Singapore’s MAS played a key role in maintaining correspondent banking relationships.
• Box 6: Alternative solutions such as local clearing systems and digital platforms are being explored.

Figures and Tables

• Figure 1: Causes of CBR termination or restriction in one country.
• Figure 2: Summary of steps for regulating and supervising remittance markets.
• Figure 3: Database architecture used for tracking CBRs.
• Figure 4: KYC utility architecture.
• Figure 5: Current and alternative settlement flows.
• Table 1: Summary of CBR closures in one surveyed country.
• Table 2: Remittance operating account closures from 2010-2017 in one country.

This report serves as a valuable resource for policymakers, regulators, and financial institutions seeking to understand and mitigate the effects of derisking in emerging markets.