2016年-FSB全球金融稳定委员会_FSB_action_plan_to_assess_and_address_the_decline_in_correspondent_banking_24页_527kb

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

Core Content

The Financial Stability Board (FSB) developed an action plan in 2015 to address the decline in correspondent banking relationships, which poses risks to international payment systems, financial inclusion, and the stability of the global financial system. The plan includes four key elements: data collection and analysis, clarifying regulatory expectations, domestic capacity-building in affected jurisdictions, and strengthening due diligence tools for correspondent banks.

Main Points and Key Information

1. Data Collection and Analysis

• Objective: To better understand the causes, effects, and trends of the decline in correspondent banking relationships.
• Key Activities:
  • The FSB launched a survey in September 2016, collecting anonymised data from over 300 banks in 50 jurisdictions.
  • SWIFT provided data for the CPMI report in July 2016 and agreed to update it by January 2017, with further updates until end-2018.
  • The survey aims to gather detailed information on:
    • Causes and consequences of the decline, including impacts on specific customer types (e.g., NGOs, remittance companies).
    • Concentration levels in the correspondent and respondent banking markets.
    • Structural changes in the correspondent banking network, such as reliance on smaller or non-local correspondents.
• Deliverables for 2017:
  • FSB will publish the survey findings and SWIFT data update by April 2017.
  • FSB and SWIFT will define a process for ongoing monitoring of trends.
  • World Bank will present country studies on the impact of the decline.
  • IMF will deepen its research on payments flows and trade finance.

2. Clarifying Regulatory Expectations

• Objective: To reduce confusion and unnecessary burdens on banks, thereby preventing the premature termination of correspondent banking relationships.
• Key Activities:
  • FATF Guidance (October 2016):
    • Clarifies that financial institutions are not required to conduct customer due diligence on the customers of their respondent bank clients (i.e., "know your customer’s customer").
    • Emphasises that enhanced due diligence should be risk-based and proportional to the identified risks.
    • Highlights that not all correspondent banking relationships carry the same risk, and that "de-risking" based on customer class rather than individual risk is discouraged.
    • Encourages ongoing dialogue between correspondent and respondent institutions to improve AML/CFT controls.
  • BCBS Guidance (November 2016):
    • Published revised guidance for consultation, in coordination with SWIFT and the Wolfsberg Group.
    • Focuses on improving the quality of payment messages and the use of KYC utilities to avoid duplication.
• Deliverables for 2017:
  • BCBS will publish its revised guidance by June 2017.
  • FATF will finalise its work on the definition of correspondent banking and issue best practices on information sharing and customer due diligence.

3. Domestic Capacity-Building

• Objective: To strengthen AML/CFT frameworks and supervisory capabilities in jurisdictions where respondent banks are affected.
• Key Activities:
  • FSB will develop a communication strategy to help jurisdictions build trust with the international community.
  • A workshop will be held in Q3 2017 to share lessons learned and coordinate capacity-building efforts.
  • CBCG members and other official sector actors will update their inventory of technical assistance semi-annually.
  • Collaboration between the private and public sectors will be encouraged to share updates on capacity-building activities.
• Deliverables for 2017:
  • FSB will publish a communication strategy by March 2017.
  • CBCG will hold a meeting in April 2017 to review progress.
  • FSB will report on progress to the G20 Summit in July 2017.

4. Strengthening Tools for Due Diligence

• Objective: To improve the efficiency and transparency of due diligence processes in correspondent banking.
• Key Activities:
  • SWIFT and the Wolfsberg Group are working on an action plan to standardise the use of payment messages, including:
    • What data should be included in payment messages.
    • How to incorporate the Legal Entity Identifier (LEI) in payment messages (optional).
    • Where to place beneficiary and ordering customer information in data fields.
  • GLEIF and SWIFT are expected to implement an initial BIC-to-LEI mapping table by June 2017.
  • By end-2017, CPMI and CBCG will discuss with the International Organization for Standardization (ISO) on defining a standardised minimum set of information to be collected by KYC utilities.
• Deliverables for 2017:
  • SWIFT and Wolfsberg Group will develop an action plan for strengthening market guidance by June 2017.
  • GLEIF and SWIFT will implement a BIC-to-LEI mapping table by June 2017.

Other Deliverables for 2017

• FSB will enhance its public website with a dedicated page on correspondent banking by January 2017.
• A joint meeting involving FSB, FATF, and GPFI will be coordinated with private sector representatives to discuss remittance services and remaining challenges.