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 it's appropriate to expect banks and financial institutions to implement detailed risk monitoring obligations in relation to trade finance transactions? Do you think the expense of these risk monitoring programs will ultimately deter banks and financial institutions from engaging in international trade financing? Why/why not?