2015年-世界发展银行全球_Withdrawal_from_Correspondent_Banking___Where_Why_and_What_to_Do_About_It_62页_1mb

Summary of "Withdrawal from Correspondent Banking: Where, Why, and What to Do About It"

Core Content

This report, prepared by the World Bank Group in 2015, examines the phenomenon of withdrawal from correspondent banking relationships (CBRs), particularly the decline in foreign CBRs by large international banks. It explores the implications of this trend for financial inclusion, the affected client segments, and the possible drivers behind the withdrawal. The report also offers recommendations for policymakers and financial institutions to mitigate the negative consequences.

Main Findings

a. Overall Trend in Correspondent Banking Relationships

• Decline Observed: Roughly half of the banking authorities and slightly more local/regional banks reported a decline in foreign CBRs.
• Large International Banks: 75% of large international banks indicated a decline.
• Most Affected Region: The Caribbean is the region most severely impacted by the decline.
• Not Uniform: The trend is not consistent across all regions and jurisdictions.

b. Impact on Products and Services

• Most Affected Services:
  • Clearing and settlement
  • Cash management
  • International wire transfers
  • Trade finance (for banking authorities and local/regional banks)
• Currency Impact: USD transactions are most affected, followed by EUR, GBP, and CAD.
• Client Segments: Money transfer operators, small and medium domestic banks, and small and medium exporters are most affected. Other impacted segments include retail customers, international business companies, and e-gaming/gambling operators.

c. Client Segments Most Significantly Affected

• Money Transfer Operators: Most affected due to their reliance on correspondent banking for cross-border transactions.
• Small and Medium Domestic Banks: Struggle with access to international payment services.
• Small and Medium Exporters: Face challenges in receiving and managing foreign currency payments.
• Retail Customers and International Business Companies: Also experience reduced access to financial services.

d. Possible Causes of Decline in Foreign CBRs

• Business-Related Drivers:
  • Compliance costs
  • Excessive risk
  • Profitability concerns
• Regulatory and Risk-Related Drivers:
  • AML/CFT concerns
  • Sanctions regimes
  • Risk of ML/FT
• Regulatory Focus: Banking authorities and large banks emphasize regulatory and risk factors, while local/regional banks focus more on economic rationale.

e. Finding Replacements/Alternative Arrangements

• Alternative Channels: Most financial institutions reported being able to find replacements, though the cost and time involved can be significant.
• Nested Accounts: Uncertainty exists regarding whether nested accounts are being used as a substitute, with concerns about transparency and risk.

f. KYCC and Nested Accounts

• KYCC Obligations: Large banks do not consider themselves explicitly obligated to conduct KYCC, but may do so under certain risk-based circumstances.
• Need for Clarity: Supervisors should provide clear guidance on when and how KYCC should be applied.
• Nested Accounts: These may reduce transparency and increase risk, as the ultimate customer may not be fully aware of their transaction history.

Conclusions and Recommendations

a. Risk-Based Approach

• Supervisors should ensure a risk-based approach to correspondent banking relationships and clarify acceptable levels of risk tolerance.

b. Effective Implementation of AML/CFT Standards

• Countries must ensure that their legal and regulatory AML/CFT frameworks are robust and that financial institutions are effectively supervised.
• The World Bank offers capacity-building tools to assist in national risk assessments.

c. Clarity on KYCC Obligations

• Supervisors should provide detailed guidance on the extent and conditions under which KYCC should be applied.
• Clear communication is essential to prevent misinterpretation.

d. Improve Information Position

• Correspondent banks should use KYC utilities and Legal Entity Identifiers (LEIs) to reduce compliance burdens.
• Countries should publish national risk assessments to inform international partners of their AML/CFT commitments and risks.

e. Consider Alternatives to Termination

• Correspondent banks should consider placing limits or trial periods instead of terminating relationships.
• Extended notice periods (at least three months) are recommended to allow for transition and risk management.

f. Monitor CBR Status

• Authorities and financial institutions should proactively monitor CBR developments within their jurisdiction and globally.
• Smaller jurisdictions, with fewer institutions, are particularly vulnerable to CBR trends and should be prioritized in monitoring efforts.

Key Information

• Survey Scope: The report is based on surveys of 110 banking authorities, 20 large banks, and 170 local/regional banks.
• Data Sources: Surveys, high-level fora, and follow-up discussions.
• Focus: The report does not aim to provide a comprehensive quantitative analysis but seeks to clarify the extent of CBR withdrawal and its implications.
• De-Risking Debate: The term "de-risking" is used to describe the withdrawal from CBRs, driven by both economic and regulatory concerns.
• Regional Impact: The Caribbean, Europe and Central Asia, and some African and Middle Eastern jurisdictions are most affected.
• US Dominance: The US is the most frequently mentioned jurisdiction where CBRs have been terminated or restricted.

Final Note

The report emphasizes that the withdrawal from correspondent banking is a complex issue with both legitimate and problematic implications. It calls for a collaborative approach between public and private sectors to ensure that financial inclusion is not compromised and that the risks associated with CBR withdrawal are managed effectively.