代理银行关系和贸易

April 2024UNCTAD/PRESS/PB/2024/1 (No. 115) Correspondent bankingrelationships and trade K E Y P O I N T S Anti-money laundering and countering financing of terrorism (AML/CFT)regulations are essential to combating financial crimes and ensuring theintegrity of the financial system. Limited capacity in developing countries to implement AML/CFT raisescompliance risks and costs for banks, leading to a decline in correspondentbanking relationships (CBRs). Least Developed Countries (LDCs), Landlocked Developing Countries, andSmall Island Developing States (SIDS), that lose more CBRs experiencedlarger reductions in export growth. Efforts are required to reduce divergence in the banks’ implementationcapacity and step-up support for LDCs, LLDCs, and SIDS. Correspondent bankingrelationships and trade Banks often use intermediary banks through CBRs to enable cross-borderpayments. These relationships are, therefore, critical for internationaltrade transactions that rely on those payments. In recent years, CBRshave declined in many developing economies, and the de-risking strategyof some banks contributes to this trend. This decline in CBRs creates achallenge for LDCs, LLDCs, and SIDS to conduct trade. This brief examinesthe cause of declining CBRs, and presents a preliminary assessment ofhow it can affect trade, and proposes possible pathways of action. What are CBRs Correspondent banking involves a financial institution (the correspondent) thatprovides banking services to another financial institution (the respondent). TheCBR is the agreement authorizing the correspondent bank to provide financialservices on behalf of another bank in a different country. Banks use CBRs tofacilitate a range of international transactions and services, including cross-borderretail payments1, cross-border remittance transfers, trade finance, and providingdocuments supporting transactions.2 According to the Bank of England, theglobal value of cross-border payments will increase from $150 trillion in 2017 toover $250 trillion by 2027.3The majority of those transactions will be done throughcorrespondent banking. Bankswith a CBR operate internationally and must comply with variousinternational financial requirements, including the AML/CFT regulations and thoseset by the authorities governing the currencies they settle in, such as the US dollarand the Euro. For instance, in the European Union, the Anti Money LaunderingDirective, initially enacted in 2015 and last amended in 2018, serves as a key pillarin anti-money laundering and countering terrorism.4These regulations mandateenhanced due diligence for banking relationships and transactions involving high-risk third countries. Following the global financial crisis of 2008, increased enforcement of AML/CFTregulation created a challenge for some banks in developing countries to meetcompliance standards.5Some of these banks have inadequate resources to complywith these requirements effectively, and some have limited capacity to implementthe AML/CFT regulation by conducting a risk assessment for their consumers. The Financial Action Task Force (FATF) has proposed a global standard for AML/CFT, which employs a risk-based approach that allows banks to address moneylaunderingand financing terrorism.6 These international standards are thenimplemented at the national level, with each country interpreting and adaptingthem to local conditions. Both correspondent and respondent banks operatinginternationally are subject to the resulting ambiguity and inconsistencies in AML/CFT regulations across jurisdictions.7 As a result, those banks face a compliance risk that may raise costs in four areas: (i)the sanction and penalty risks that heighten cross-border exposure, (ii) increased duediligence on customers, (iii) the lack of harmonization in compliance requirementsacross jurisdictions, and (iv) constantly evolving compliance requirements continuewhich banks need to keep up with them.8To avoid compliance risks, certain bankshave de-risked entire categories of clients based on risk profiles or geographiclocations. De-risking means a situation where financial institutions terminate orrestrict CBRs to avoid risk instead of conducting risk analyses and applying risk-based approaches.9The de-risking strategy, in turn, had led to the decline ofCBRs in some developing countries.10 Declining CBRs The Bank for International Settlements (BIS) has measured the number of activecorrespondents since 2011, and declining trends have been observed across allregions, with the biggest falls in Latin America, the Caribbean, and Oceania.11Thedecline in that number would mean fewer CBRs handle a larger share of cross-border transactions, concentrating the market on larger banks that can maintainthe global network.12 In addition, the market concentration among correspondent banks results inless competition, fewer available payment channels, and longer payment chains.Consequently, this has impacted the costs of inte