Why is correspondent banking high-risk for money laundering, and what are nested accounts?
An advanced Risk & Compliance question — expect it in final rounds and case-heavy interviews (IB, PE, Big-4 Transaction Services).
THE SHORT ANSWER
Correspondent banking — one bank providing accounts/services to another bank to access a market or currency — is high-risk because the correspondent doesn't have a direct relationship with the respondent's underlying customers, so it can't see who's really moving money; it relies on the respondent's AML controls, which may be weaker, in higher-risk jurisdictions. Nesting (or 'downstream correspondent') is the acute risk: the respondent bank lets other institutions — that the correspondent never assessed — access the correspondent account through it, effectively giving unknown third banks indirect access to the financial system. That's how illicit flows enter via a back door. Controls: enhanced due diligence on the respondent (ownership, AML program, regulatory standing, Wolfsberg questionnaire), understanding the respondent's customer base and whether it permits nesting, prohibiting payable-through-account abuse, transaction monitoring on the correspondent flows, and not banking shell banks. It's a focus of FATF and major enforcement actions.
WHAT INTERVIEWERS LISTEN FOR
- ✓No visibility of the respondent's underlying customers
- ✓Reliance on respondent's (possibly weaker) AML controls
- ✓Nesting: unknown third banks access via the respondent's account
- ✓EDD on respondent, restrict nesting, monitor flows, no shell banks
COMMON MISTAKES
- ✗Treating a respondent bank like a normal customer
- ✗Unaware of nesting/downstream risk
- ✗Banking shell banks or ignoring payable-through abuse
Reading isn't the same as answering under pressure.
Interviewers don't hand you the model answer — you deliver yours on a clock. Practice this and 1,000+ questions with AI feedback on every answer.
RELATED QUESTIONS
- Explain sanctions screening.
- Explain the fraud triangle and how compliance programs use it.
- How would you design an AML transaction monitoring system?
- How would you tune an AML transaction-monitoring system that is generating an unmanageable volume of false-positive alerts?
- Why is identifying the ultimate beneficial owner (UBO) central to CDD, and how do you handle complex ownership structures?
- What is trade-based money laundering, and what red flags would you train transaction reviewers to spot?