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.

1. BOTW is not subject to any enforcement actions for AML/CTF or Sanctions violations.
2. 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.  
3. As part of a US-chartered Bank, BOTW is not required to provide a USA PATRIOT Act Certification.
4. 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
5. BOTW does not provide services of any kind to shell banks or to companies that issue bearer shares.
6. BMO has a duly authorized BSA Officer, Adam Schabes. At Bank of the West, John McCarthy is the AML Officer and Head of Financial Security Domain. Mr. McCarthy has held executive BSA/AML roles, including BSA/OFAC Officer, at multiple global and regional U.S. financial institutions.
7. 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.
8. BOTW adheres to the Wolfsberg Transparency Principles and the appropriate usage of SWIFT 202/202COV and 205/205 COV message formats.

• BOTW's overall AML statement and completed Wolfsberg questionnaire are available at: AML Statement
• BMO Fact Sheet