By SanctionsAI team · Updated 2026-08-09
How to manage correspondent banking sanctions risk
Correspondent banking is high-risk because you process transactions for other banks' customers whom you cannot directly screen.
The nested account problem
Your respondent bank's customers (nested banks and their customers) may be sanctioned entities. You process their transactions without knowing their identity.
| Risk level | Respondent profile | Controls |
| Low | Regulated bank, FATF-compliant | Standard screening, annual review |
| Medium | Moderate-risk jurisdiction | Enhanced screening, semi-annual |
| High | High-risk jurisdiction, weak AML | Transaction-by-transaction, quarterly |
| Unacceptable | Under sanctions | Terminate relationship |
Nested account risk: The biggest correspondent banking sanctions risk. Insist on transparency about nested relationships.
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Frequently Asked Questions
- What is correspondent banking sanctions risk?
- Risk that correspondent relationships expose you to violations through respondent banks' customers.
- What are nested accounts?
- Accounts your respondent holds for other banks. You process transactions without knowing the nested banks' customers.
- How do I screen correspondent transactions?
- Screen respondent bank at onboarding. Use SWIFT fields for transaction-level screening.
- Should I terminate high-risk relationships?
- If unacceptable (under sanctions), yes. For elevated risk, apply enhanced monitoring.
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