EML subjects foreign counterparties, bank and corporate, to comprehensive acceptance and monitoring due diligence procedures. Due diligence criteria requires satisfactory determination that the counterparty:
- Has a legitimate business structure
- Operates in an international forum that requires the ability to obtain and/or sell local currency to support its operational needs
- Is properly registered and licensed, if local law requires
- Operates under the laws and authority of the government where it is licensed, including regulations of the central bank
- Does not appear on the list of Specially Designated Nationals of the Office of Foreign Asset Control of the United States Department of the Treasury (OFAC) as well as 26 other internationally recognized data files, including SDN lists of the Bank of England, Bank of Canada, the European Union, the United Nations, among others.
- Maintains hard currency correspondent accounts at major financial institutions in the U.S. or Western Europe for settlement of the USD or EUR side of the trade.
