The regime it operated was “fair and effective”, the US department said in a statement and factsheet, with about 95% of anti-money laundering (AML), countering the finance of terrorism (CFT) and sanctions compliance problems getting corrected through cautionary letters or other guidance without the need for an enforcement action or penalty.
The statement is aimed at countering moves by international banks to withdraw correspondent banking services from jurisdictions or certain regions for de-risking reasons.
“The rare but highly visible cases of large monetary penalties or settlements for AML/CFT and sanctions violations have generally involved a sustained pattern of reckless or willful violations over a period of multiple years and a failure by the institutions’ senior management to respond to warning signs that their actions were illegal. These large cases did not represent small or unintentional mistakes,” it said.
The fact sheet also dispelled “certain myths” about US supervisory expectations, “notably that there is no general expectation for banks to conduct due diligence on the individual customers of foreign financial institutions”.