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Is cross-border exchange business a reference factor for bank customers’ money laundering risks?

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Cross-border collection and remittance are common businesses of banks. However, when capital flows involve overseas, it is difficult for domestic banks to grasp the detailed information of overseas capital flows, which leads to banks facing higher risks of money laundering. In case of cooperation, Overseas financial institutions that collect remittances have omissions in anti-money laundering work, and money laundering risks are more easily transmitted from overseas banks to domestic banks. Therefore, the People's Bank of China requires banks to master the basics of overseas remittance collection when engaging in cross-border remittance collection business. Money laundering risk management and control is carried out at three levels: information, establishing criteria for selecting overseas correspondent banks, and defining which overseas correspondent banks are high-risk customers for money laundering.

When a bank receives remittances from abroad and finds that any of the three pieces of information including the name, account number and address of the remitter is missing, it should immediately request the overseas bank to provide additional information. It should be noted that, If an overseas correspondent bank requires the provision of customer identity, transaction background and other information in addition to remittance information, corporate customer registration information, etc. on the grounds of anti-money laundering and anti-terrorist financing, according to the Bank Anti-Shaft [2018] No. 19 The Anti-Money Laundering Bureau of the People's Bank of China issued the "Guidelines for the Management of Money Laundering and Terrorist Financing Risks of Legal Person Financial Institutions (Trial)". Banks must obtain authorization and consent from customers before they can provide it. If the customer does not agree or does not obtain the customer's authorization and consent, the bank shall not provide further information to the overseas correspondent bank.