Section 10

identify and verify the identification of respondent institutions with which they conduct correspondent banking relationships;

collect information on the nature of the respondent institution’s activities;

based on publicly-available information, evaluate the respondent institution’s reputation and the nature of supervision to which it is subject;

obtain approval from senior management before establishing a correspondent banking relationship;

evaluate the controls implemented by the respondent institution with respect to anti-money laundering and combating the financing of terrorism;

establish an agreement on the respective responsibilities of each party under the relationship;

in the case of a payable-through account, ensure that the respondent institution has verified its customer’s identity, has implemented mechanisms for ongoing monitoring with respect to its customers, and is capable of providing relevant identifying information on request;

not enter into or continue business relations with a shell bank; and

not enter into or continue business relations with a respondent financial institution in a foreign country if the respondent institution permits its accounts to be used by a shell bank.

lnability to fulfil customer identification obligations.