Artikel 36 Spezifische verstärkte Sorgfaltsmaßnahmen bei grenzüberschreitenden Korrespondenzbankbeziehungen

This article sets out the enhanced due diligence obligations that apply specifically to credit institutions and financial institutions when entering into cross-border correspondent relationships with third-country respondent institutions.

It builds directly on the standard customer due diligence measures in Article 20, layering on additional requirements that reflect the heightened risk these relationships can carry.

The core thrust is that institutions must actively understand, assess, and document the respondent before and during the relationship — not simply apply routine checks.

Important points:

• When entering a cross-border correspondent relationship with a third-country institution, gather sufficient information on the respondent's business and reputation, assess its AML/CFT controls, obtain senior management approval, and document the responsibilities of each party.
• For payable-through accounts specifically, satisfy yourself that the respondent institution has verified and performed ongoing due diligence on customers with direct access to the correspondent's accounts, and that it can provide that data upon request.
• If you decide to terminate a cross-border correspondent relationship for AML/CFT policy reasons, document that decision.