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Benjamin W. Hutten Quoted in Article, “US Banks Frequently Fail to Identify All Correspondent Clients: Regulator”


Benjamin W. Hutten

Benjamin W. Hutten was quoted on April 21, 2017 in an article on regarding “US Banks Frequently Fail to Identify All Correspondent Clients: Regulator.” The article discussed the struggle by U.S. financial institutions to properly identify and monitor foreign banks and clients with correspondent transactions, which FinCEN has required since 2008. The article stated, “The U.S. government’s anti-money laundering examination manual defines ‘correspondent account’ as any ‘formal’ or ‘regular’ product or service that a U.S. financial institution offers a foreign bank, such as U.S. dollar deposit ‘or other transaction or asset account… credit account or other extension of credit.’”

Hutten identified that the difficulty lies with assessing what these terms mean. He noted, “The lack of clarity poses a common difficulty and potential regulatory pitfall for financial institutions involved in global commerce.” Hutten added, “The difficulty lies in figuring out each case and deciding how much time or expense you are going to put into tracking this information.”