Kenneth Rijock

Kenneth Rijock

Tuesday, August 7, 2012

DO WE NOW NEED TO GET ANTI-STRIPPING AFFIDAVITS FROM CORRESPONDENT BANKS ?



In light of the sordid actions of ING, HSBC, and Standard Chartered Bank, in admittedly "stripping" out all indicia of Iranian banks or companies, or those of other rogue nations, from their wire transactions coming into the USA, and substituting information specifically designed to evade OFAC alarms, must US banks now compel their correspondents to execute affidavits like this;

                                           



                                      S  A  M  P  L  E   A F F I D A V I T
                    (It is strongly suggested that this be prepared by your outside bank counsel)



(1) My name is __________, and I am the Managing Director of XYZ Bank (hereinafter "the Bank"), and this Affidavit is being made upon personal knowledge.

(2) XYZ Bank, as a matter of policy, does not engage in removing (stripping) out any information from wire transfers handled by the bank, nor does it accept transactions where information has been deleted, changed, disguised, or altered, in any way.

(3) XYZ Bank's staff, including, but not limited to, the Wire Department, the Operations Division, and the Compliance Department, all follow the above policies, which are included in the bank's Compliance Manual, relevant portions of which are attached hereto as Exhibit A.

(4) [Such additional details as your counsel deems relevant].

SWORN TO and subscribed before me, the undersigned Notary Public....

                                                                                            __/s/___________________

Should we start requiring this ? I welcome your opinions.
miamicompliance@gmail.com


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