On December 17, 2009, the U.S. federal banking supervisors[1], in consultation with the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN), issued an interagency guidance that sheds some light on the U.S. regulators’ view about the use of the new SWIFT MT 202 COV messages and discusses the supervisors’ approach to reviewing an institution’s risk management practices with respect to cross-border funds transfers.
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