AML/BSA Due Diligence Information


This page is intended to facilitate the periodic due diligence review process for financial institutions with whom Bank of the West (hereafter, “BOTW”) holds accounts or exchanges SWIFT RMA Keys.

The information, links and documents provide answers to common inquiries and attest to BOTW’s full compliance with applicable Anti-Money Laundering (AML) and Sanctions laws. Any additional requests must be submitted to BSAProgram@bankofthewest.com for review on a case-by-case basis.

General Information

  1. BOTW is a subsidiary of BancWest Corporation, which itself is a subsidiary of BNP Paribas, headquartered in Paris, FR. More information about BNP Paribas, including its license, registration and ownership, as well as the Group AML policy, can be found at: https://group.bnpparibas/en/publications
  2. BOTW is not subject to any enforcement actions for AML/CTF or Sanctions violations.
  3. BOTW is OFAC-compliant and does not employ, or facilitate business with, Specially Designated Nationals (SDNs) or any other individuals or entities subject to US or other applicable Sanctions.  
  4. As a US-chartered Bank, BOTW is not required to provide a USA PATRIOT Act Certification.
  5. BOTW does not offer the following banking services:
    1. Nested/downstream correspondent accounts
    2. Payable through accounts
    3. Anonymous/private banking
    4. Cross-border bulk currency shipments
    5. Payable upon proper ID transactions
  6. BOTW does not provide services of any kind to shell banks or to companies that issue bearer shares.
  7. BOTW has a duly authorized BSA Officer, Tracy Brock, who has been a compliance professional since 1986. Mr. Brock first served as a BSA/AML/CTF (Bank Secrecy Act/Anti-Money Laundering/Counter Terrorist Financing) Senior Compliance Officer in 2004, after having served in various roles in the broader compliance function. 
  8. BOTW has a risk-based customer due diligence program, including a robust Know Your Customer (KYC) process, and applies appropriate controls across all business units. Customers identified as presenting higher levels of AML risk undergo an annual Enhanced Due Diligence review.
  9. BOTW adheres to the Wolfsberg Transparency Principles and the appropriate usage of SWIFT 202/202COV and 205/205 COV message formats.

Additional Resources