Record keeping in correspondent banking relationships (Reform)

Learn about the obligations and record keeping requirements for financial institutions entering into a correspondent banking relationship.

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Timeframes

All timeframes in this guidance start the day after the relevant event or action takes place. For example, if an assessment is completed on a Monday, any deadline measured in business days will start from Tuesday.

Before entering a correspondent banking relationship

This section refers to the Act section 96(1).

If your financial institution plans to enter into a relationship with another financial institution involving a vostro account, you must:

  • conduct a due diligence assessment as set out in the Anti-Money Laundering and Counter-Terrorism Funding Rules (the Rules)
  • make a written record of the assessment
  • get approval from a senior officer of your institution, who must consider the relevant matters in the Rules. 

After entering the relationship

This section refers to the Act section 96(2).

If you proceed with the relationship, within 20 business days you must prepare a written record stating what:

  • your institution is responsible for under the relationship
  • the other institution is responsible for.

Ongoing obligations

This section refers to the Act section 96(3).

While the relationship continues, your institution must conduct further due diligence assessments as required under the Rules. For each assessment, you must:

  • make a written record within 10 business days after completing the assessment
  • have the written record reviewed by a senior officer within 20 business days after the preparation of the record. 

The senior officer must decide whether your institution should continue the relationship.

Record keeping retention

This section refers to the Act section 117.

You must keep all records related to correspondent banking relationships for 7 years from the date they’re made.

This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened. 

The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.

This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.

Last updated: 17 Oct 2025
Page ID: 1301

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