Enhanced Due Diligence on a Correspondent Bank (PlantUML)
EDD triggered by nested payment alerts, running through Wolfsberg questionnaire, sanctions screening and an MLRO exit decision.
Rendering…
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@startuml
title Enhanced due diligence - correspondent banking relationship
start
:Trigger - transaction monitoring alert on nested payments;
:Pull 12 months of MT103 and MT202 traffic;
if (Respondent in a FATF grey-list jurisdiction?) then (yes)
:Request the Wolfsberg correspondent banking questionnaire;
:Verify licence, ownership chain and PEP exposure;
else (no)
:Refresh the standard periodic review evidence;
endif
:Screen the underlying counterparties for sanctions and adverse media;
if (Sanctions nexus identified?) then (yes)
:Freeze and escalate to the MLRO the same day;
:File a suspicious activity report within the reporting window;
:Recommend exit and off-boarding;
stop
else (no)
endif
if (Residual risk still rated high?) then (yes)
:Impose payment purpose codes and monthly volume caps;
:Move the relationship to a 6 month review cycle;
else (no)
:Return to the 24 month review cycle;
endif
:Record the rationale in the customer risk assessment;
stop
@enduml