Antiriciclaggio “fra pari”: profili critici del Know Your Customer nei rapporti interbancari

International payments are cleared and settled mainly through correspondent banks. Correspondent banking is essential to international finance and commerce. It has become more concentrated, negatively affecting market integrity, financial inclusion and economic prosperity. Typically, a correspondent bank has only limited information about the respondent bank’s customers and the nature of their transactions. Unclear regulatory expectations are particularly relevant in the case of requirements on correspondent banks’ knowledge of their respondent banks’ customers – the so-called Know Your Customer’s Customer (KYCC). This lack of clarity may create incentives to accelerate de-risking. The 2021 EU AML Package could provide an opportunity to address this regulatory issue. The analysis focuses on the current framework, suggesting possible changes to the proposed AML regulation under discussion.