It is no secret that U.S. correspondent banking relationships
are indispensable to global commerce. Indeed, access to the U.S.
financial system through correspondent banking is integral to
foreign banks and to their customers, who often depend on the U.S.
dollar as the anchor currency for their deals. At the same time,
U.S. banks are under intense pressure (more than ever before) by
regulators and law enforcement to quickly detect and report
suspicious activity, and ensure that they are not conduits for
illicit funds originating in foreign jurisdictions, and passing
through correspondent accounts held for foreign banks.
To that end, in what is certainly not a new phenomenon, U.S.
banks are keeping a close watch over their correspondent banking
relationships, and quickly moving to exit relationships at the hint
of impropriety. Moreover, it is well documented that some U.S.
banks are "de-risking" not because of a specific event
but because of the overall financial crime
