AML compliance for micro-cap forex brokers - how are you handling correspondent banking due diligence?
Hey everyone, fairly new to the compliance side of a smaller shop, specifically a micro-cap forex broker trying to navigate AML. We're growing, which is great, but it also means our correspondent banking relationships are getting more scrutiny, particularly with new banks. I'm finding it tough to get a clear picture of what 'adequate' due diligence looks like from their side when they're assessing us for our AML policies and procedures, especially regarding our client base. It feels like a moving target sometimes, and the amount of data and documentation they're asking for can be pretty overwhelming for a small team. Are there any specific frameworks or best practices you've found helpful in preparing your AML program documentation to satisfy larger correspondent banks, particularly around source of wealth/funds for your clients? It feels like we're constantly playing catch-up.
This is a tough one, especially for smaller brokers. We've found that having all your internal policies and procedures absolutely buttoned up, and being able to clearly articulate them, goes a long way. Have you considered bringing in a consultant who specializes in correspondent banking due diligence for FX?