The USA PATRIOT Act’s (PDF) section on foreign correspondent banks has always contained a trigger (in section 312(a)(1)(2)(a)(2) (PDF)) that requires banks and some other regulated financial institutions complying with U.S. law to carry out greater scrutiny, including enhanced due diligence, particularly regarding whether the correspondent bank has nested relationships and, as appropriate, details about those relationships. Now, FinCEN has explicitly identified eleven countries as being subject to that trigger, requiring extra scrutiny, namely: Algeria, Ecuador, Ethiopia, Indonesia, Kenya, Myanmar, Pakistan, Syria, Tanzania, Turkey, and Yemen. The specific language of the trigger in question, as expressed in the Patriot Act's underlying regulation for section 312 on correspondent banking, 31 CFR 1010.610(c)(2), for the extra scrutiny, is: "A banking license issued by a foreign country that has been designated as non-cooperative with international anti-money laundering principles or
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