The Wolfsberg Group, Anti-Money Laundering Principles for Correspondent Banking The Wolfsberg Group, Wolfsberg Frequently Asked Questions ("FAQs") on Correspondent Banking FinCEN, Section 312 of the USA PATRIOT Act: Final Regulation and Notice of Proposed Rulemaking Section 312 of the PATRIOT Act In the Matter of Merchants Bank of California, U.S. Dept. of the Treasury, Number 2017-01, pp 1-3; 11-12 Monetary Authority of Singapore, Guidance on Anti-Money Laundering and Countering the Financing of Terrorism Controls in Trade Finance and Correspondent Banking, October 2015, pp. 1-21 Diana Joskowicz and Peter Hardy, Regulatory Round Up: FinCEN Solicits Comments on Due Diligence for Correspondent and Private Bank Accounts, October 15, 2020, Money Laundering Watch

Do you think the enhanced due diligence regulations imposed by FinCEN on correspondent banking activities under to the Bank Secrecy Act impose burdens on banks and financial institutions that are out of proportion to the risks they are intended to address? Why/why not?