By Denis Kruger, Head of Sub-Sahara Africa, SWIFT

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Correspondent banking enables banks to access products and services which might otherwise be unavailable. By enabling cross-border transactions and access to overseas products, correspondent banking plays an important role in the global payments landscape.

Increasingly, however, banks around the world are reviewing and rationalising their correspondent banking relationships. This trend, known as de-risking, is primarily being driven by concerns about anti-money laundering, counter-terrorist financing and the associated regulatory pressures; another contributory factor to this dynamic is the cost associated with maintaining multiple relationships.

IMPACT OF DE-RISKING

The impact of this trend is being felt in a number of regions – including Africa. Research published by The World Bank in November 2015, Withdrawal from Correspondent Banking, found that over half of the banks surveyed reported a moderate or significant decline in their correspondent banking relationships in Africa.

Meanwhile, SWIFT data released last year shows that many countries in Africa have seen a reduction in their foreign counterparties – in other words, the foreign banks with whom African banks transact overseas. Angola, for example, lost more than 37% of its foreign counterparties between 2013 and 2015. Mauritius has also seen a sharp decline of 18%.

Interestingly, even while Nigeria’s international banking network has had limited de-risking, its local banks have at the same time been cutting their own relationships with other African banks, financial services providers or counterparties perceived to be more risky.

De-risking can have significant consequences for the affected countries. Cross-border trade may be significantly impeded if countries are cut off from the global financial system. Products and services such as international wire transfers, cash management services and trade finance may become difficult to access.

For individual banks, the prospect of being de-risked presents a number of challenges. While some banks may be able to find alternative banking partners, others may find themselves cut off entirely. Moreover, securing new relationships takes time and money – and banks may find that any new arrangements are based on less favourable terms and conditions.

UNINTENDED CONSEQUENCES

Banking customers may also be adversely affected. Without access to correspondent banking services, businesses and individuals may be unable to import goods from overseas; in turn, problems with the supply chain could push some businesses into distress and lead to greater levels of unemployment. In some cases, consumers may be unable to send remittances to family members overseas.

Reduced access to traditional banking channels may force people to find other ways of making and receiving payments, such as using informal money services or, indeed, physically transporting cash across borders. However, these unregulated channels may bring additional risks and leave people more vulnerable to criminal activity. A shift away from traditional channels could even create additional opportunities for money laundering and terrorist financing activities to thrive.

De-risking could also have a negative impact on financial inclusion rates. Typically it is the smaller, local banks that are de-risked. Therefore de-risking could adversely impact the services available to the poorest in society. In a continent where huge proportions of the population are unbanked, and authorities are doing all they can to increase access to formal financial services, it could be that the poorest members of society are those who will suffer most. 

There could be further unintended consequences. A paper from the Committee on Payments & Market Infrastructures (CPMI) demonstrates that while the number of active correspondents is shrinking the volume of transactions is still rising, showing that as one part of the banking network becomes unavailable payments find another route. Taken together, the decrease in the number of active correspondents and the increase in volumes suggest heightened concentration of banking relationships, a trend which may have implications for the financial industry’s systemic health.

ADDRESSING THE ISSUES

At the industry level, different approaches are being explored to overcome these issues. Greater levels of collaboration and information sharing between banks, regulators and law enforcement may help, with bodies such as the Committee of Chief Compliance Officers of Banks in Nigeria (CCCOBIN) helping to foster co-operation. For individual banks, meanwhile, there are a number of steps that can be taken to reduce the likelihood of being de-risked, or to mitigate the impact of de-risking if such an outcome is inevitable.

First of all, banks should understand why they may be de-risked. Factors such as the political and economic landscape in specific African countries will certainly be part of this equation. However, it is also becoming clear that banks are more likely to be affected if they provide insufficient transparency over their activities, business lines and behaviour, or if they provide such information in an inconsistent way. The more difficult it is for correspondents to access KYC or AML information, the greater the cost of doing business with a specific bank becomes.

In order to address this issue, banks can put measures in place to improve both their transparency and the consistency of their information. For example, a specific individual or department can be tasked with creating a standard data set, the so-called ‘golden copy’. This data set can then be sliced and diced before being shared with the market in different ways.

Compliance controls such as transaction screening can be used effectively, while steps can be taken to reduce the due diligence costs incurred by correspondents. Any strategies adopted should also be communicated effectively to correspondent banks.

Industry utilities such as SWIFT’s KYC Registry can help by acting as a repository of up-to-date information. With more than 2,500 financial institutions already signed up, the Registry enables banks to provide validated information on a one-time basis, making it cheaper and easier for their correspondents to access the information they need.

Such strategies are not guaranteed to succeed. In some cases, a bank will not be able to avoid being de-risked, regardless of which processes and strategies are put in place. However, by becoming more transparent about their activities and compliance measures, banks may be able to reduce the likelihood of such an outcome – or, indeed, increase their chances of securing alternative arrangements if they are de-risked.

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