As also noted in the above section on general due diligence, a bank’s resources are most appropriately directed at those accounts that pose a more significant money laundering risk. Accordingly, where a bank is required or otherwise determines that it is necessary to conduct EDD in connection with a foreign correspondent account, the bank may consider the risk assessment factors discussed in the section on general due diligence when determining the extent of the EDD that is necessary and appropriate to mitigate the risks presented. In particular, the anti-money laundering and supervisory regime of the jurisdiction that issued a charter or license to the foreign financial institution may be especially relevant in a bank’s determination of the nature and extent of the risks posed by a foreign correspondent account and the extent of the EDD to be applied.
In addition to those categories of foreign banks identified in the regulation as requiring EDD, banks may find it appropriate to conduct additional due diligence measures on foreign financial institutions identified through application of the bank’s general due diligence program as posing a higher risk for money laundering. Such measures may include any or all of the elements of EDD set forth in the regulation, as appropriate for the risks posed by the specific foreign correspondent account.
In addition, a foreign correspondent may be able to find supplementary work with a local news source in the country. Freelance foreign correspondents who are bilingual will have a major advantage; photography skills are helpful as well. Foreign corresponding is a challenging and sometimes dangerous job that often does not pay very well unless you are working for a major news organization, but for those who are passionate about the news and international travel, it can be a dream job.