The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Office of Thrift Supervision, and National Credit Union Administration, in coordination with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), have issued the attached interagency advisory concerning the embassy banking business and related banking matters. The purpose of the advisory is to provide general guidance to banking organizations regarding the treatment of accounts for foreign governments, foreign embassies, and foreign political figures.
The joint interagency statement advises banking organizations that the decision to accept or reject an embassy or foreign government account is theirs alone to make. It goes on to advise that financial institutions should be aware that there are varying degrees of risk associated with such accounts depending on the customer and the nature of the services provided, and that they should take appropriate steps to manage such risks consistent with sound practices and applicable anti-money laundering laws and regulations. The advisory also encourages banking organizations to direct questions about embassy banking to their primary federal bank regulators; thus, it is expected that you may receive inquiries from banking organizations in your district.
To ensure that the System provides consistent information on this subject, it is requested that the response to inquiries from banking organizations be coordinated through Herbert A. Biern, Senior Associate Director, Division of Banking Supervision and Regulation, at the Board.
In addition to the issuance of the advisory by the banking agencies, the U.S. Departments of State and Treasury have issued the attached joint statement on embassy banking.
Reserve Banks are asked to distribute this SR letter to the domestic and foreign banking organizations supervised by the Federal Reserve in your districts, as well as to supervisory and examination staff. If you have any questions, please contact Mr. Biern at (202) 452-2620.