Rules & Regulations
Governing Trade Services
The (Unintended) Impact on Exporters of
the Rules & Regulations Governing Banks
That Provide Trade Services
Buddy Baker
[email protected]
(312) 704-6942
Speaker Bio: Walter (Buddy) Baker
Walter (Buddy) Baker brings more than 30 years of experience in international trade finance to his current
position as Vice President and head of Global Trade Solutions Delivery for Fifth Third Bank. Fifth Third is
one of the 20 largest banks in the US and provides a full range of risk mitigation and financing products for
exporters and importers. His professional experience includes earlier stints with Atradius Trade Credit
Insurance, ABN AMRO Bank, Bank of America, Wachovia Bank, and The First National Bank of Chicago.
Buddy is a recognized expert in trade finance and makes frequent presentations for national associations of
exporters, importers, bankers, and lawyers. He designed the online training/certification programs used by
the Association of International Credit and Trade Finance Professionals (ICTF) and by the Association of
Trade and Forfaiting in the Americas (ATFA) and the trade finance sections of the certification program
used by the Finance, Credit and International Business Group (FCIB) of the National Association of Credit
Management (NACM). Mr. Baker has authored numerous magazine articles and the books Users’
Handbook to Documentary Credits under UCP600, Documentary Payments & Short-Term Trade Finance,
and The Regulatory Environment of Letters of Credit and Trade Finance. He serves as a member-at-large
of the National Letter of Credit Committee of the Bankers’ Association for Finance and Trade/International
Financial Services Association and is actively involved in establishing national and worldwide standard
practices for LCs, such as the current version of the Uniform Customs and Practice for Documentary
Credits (referred to as “UCP600”), the official ICC guide for examining letter of credit documents, called the
International Standard Banking Practices for the Examination of Documents under Documentary Credits
(“ISBP”), the eUCP supplement to the UCP dealing with electronic documents, the International Standby
Practices (“ISP98”), and Article 5 of the Uniform Commercial Code. Buddy also serves on the Board of
Directors of the Association of International Credit and Trade Finance Professionals (ICTF), a multinational
association of export credit managers, on the Advisory Council of the Institute for International Banking Law
and Practice, and on the Council on International Standby Practices.
Buddy earned his undergraduate degree at Yale University and his MBA at Northwestern. He can be
reached at (312) 704-6942 or [email protected].
Rules & Regulations - Buddy Baker
4
Rules & Regulations Pertaining to Exporting

The Uniform Customs and Practice for Documentary Credits (“UCP”)

International Standard Banking Practice for the Examination of Documents under Documentary Credits
(“ISBP”)

The eUCP

The International Standby Practices (“ISP98”)

The Uniform Rules for Demand Guarantees

Letter of credit law (e.g., Uniform Commercial Code, Article 5)

The Uniform Rules for Collections

Negotiable instrument law (e.g., Uniform Commercial Code, Articles 3 and 4)

The International Commercial Terms (“Incoterms”)

The U.N. Convention on Contracts for the International Sale of Goods (“CISG”)

Export licensing (e.g., the Export Administration Regulations (“EAR”) and International Traffic in Arms
Regulations (“ITAR”))

FX controls

Sanctions against “enemy” countries (e.g., the Office of Foreign Assets Control and U.N. sanctions)

Antiboycott regulations

Anti-Money Laundering regulations (e.g., the USA PATRIOT Act)

Anti-corruption regulations (e.g., the Foreign Corrupt Practices Act)
Rules & Regulations - Buddy Baker
5
Rules & Regulations Pertaining to Exporting

The Uniform Customs and Practice for Documentary Credits (“UCP”)

International Standard Banking Practice for the Examination of Documents under Documentary Credits
(“ISBP”)

The eUCP

The International Standby Practices (“ISP98”)

The Uniform Rules for Demand Guarantees

Letter of credit law (e.g., Uniform Commercial Code, Article 5)

The Uniform Rules for Collections

Negotiable instrument law (e.g., Uniform Commercial Code, Articles 3 and 4)

The International Commercial Terms (“Incoterms”)

The U.N. Convention on Contracts for the International Sale of Goods (“CISG”)

Export licensing (e.g., the Export Administration Regulations (“EAR”) and International Traffic in Arms
Regulations (“ITAR”))

FX controls

Sanctions against “enemy” countries (e.g., the Office of Foreign Assets Control and U.N. sanctions)

Antiboycott regulations

Anti-Money Laundering regulations (e.g., the USA PATRIOT Act)

Anti-corruption regulations (e.g., the Foreign Corrupt Practices Act)
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What Banks Are Required to Do


Block any assets of parties located in sanctioned countries and of “Specially
Designated Nationals” of those countries coming under control of the bank
Block any assets of “Designated Terrorists and Terrorist Organizations” and
“Designated Drug Traffickers and Kingpins” coming under control of the
bank

Not “implement” any letter of credit containing prohibited boycott language

Report every letter of credit containing reportable boycott language

Conduct due diligence on all “account relationships” of the bank

Report “suspicious activities”
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Sanctions
Sanctions - Introduction

Definition: Action by one or more states toward another state calculated to
force it to comply with legal obligations.

Sanctions are supposed to persuade rulers to change their military,
economic, or human rights policies, so as to end wars, civil conflicts, or other
crises that threaten international peace and security.

Sanctions are meant to bring about a change of behavior; they are not
supposed to be punishment or retribution.

The U.N. Security Council imposes sanctions to enforce international law, but
depends on member nations to actually enforce them.

The U.S. often takes independent action, usually before the U.N.
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Sanctions - An Analysis

Typically, sanctions cut off trade and investments, preventing a target country
from buying or selling goods in the global marketplace.

Sanctions aim at particular items like arms or oil.

They may cut off air traffic, suspend or drastically curtail diplomatic relations,
block movement of persons, bar investments, or freeze international bank
deposits and other property.
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U.S. Office of Foreign Assets Control
(OFAC)
Office of Foreign Assets Control
OFAC is a division of the U.S. Department of Treasury. It administers and
enforces economic and trade sanctions against hostile targets to further
U.S. foreign policy and security objectives.

“Enemy” countries

Individual sponsors of terrorism and any agency sponsoring terrorism

International narcotics traffickers
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Office of Foreign Assets Control

Many of OFAC sanctions are based on United Nations or other international
agreements. As such, they are multilateral in scope and involve close cooperation with concerned governments.

OFAC acts under Presidential wartime and national emergency powers and
under the authority granted by specific legislation to authorize imposing of
controls on trade transactions and foreign investments and even freeze
foreign assets that may come under U.S. jurisdiction.
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OFAC Sanctions Apply to…
U.S. residents or nationals
This includes
Individuals

Any partnership, corporation, company, association, or other entity organised
under U.S. law

U.S. companies’ foreign subsidiaries, partnership affiliates, branches, offices,
or other permanent foreign establishments that are controlled in fact by such
U.S. company

The government of the U.S. or any department, agency or commission
thereof; the government of any state of the U.S., the District of Columbia, the
Commonwealth of Puerto Rico, any territory of the U.S. or any subdivision,
department, agency, or commission of any such government
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Role of Banks…

U.S. banks & U.S. branches of foreign banks must comply in all respects with
the laws, policies, and regulations of the United States Department of
Treasury.

They are like a ‘front-line’ defense against foreign threats to U.S. interests.
Rules & Regulations - Buddy Baker
15
Role of Banks…

Enforce sanctions against imports and exports of any goods and services
from/to:
– Sanctioned countries
– Specially Designated Nationals (SDNs)
– Specially Designated Terrorists (SDTs)
– Specially Designated Narcotics Traffickers (SDNTs)
– Foreign Terrorist Organisation (FTOs)
– Blocked Persons (companies and individuals)

Block or freeze property and payment of any funds transfers or transactions
intended for these entities.

Report all blocked property to OFAC within 10 days of occurrence.
This does not mean the bank returns the funds or property
they’ve received. They must hold the funds/property on behalf
of the U.S. Treasury Department.
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Property…
Property includes
Money, checks, drafts, bullion, bank deposits, savings accounts, debts,
indebtedness, obligations, notes, debentures, stocks, bonds, coupons,
financial securities, BANKERS’ ACCEPTANCES, mortgages, pledges, liens
or other rights in the nature of security, property, warehouse receipts, B/Ls,
TRUST RECEIPTS, bills of sale, any other evidences of title, ownership,
LETTERS OF CREDIT, powers of attorney, goods, wares, chattels*, stock
on hand, ships, goods on ships, vendors sales agreements, land contracts,
real estate interests, lease holds, rents options, NEGOTIABLE
INSTRUMENTS, TRADE ACCEPTANCES, royalties, account payable,
patents, trademarks, copyrights, insurance policies, safe deposit boxes,
pooling agreements, contracts of any nature.
* Moveable possessions
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General & Specific Licenses

A license is a permit issued by OFAC allowing an activity that would
otherwise be prohibited by sanctions.

A General License allows certain types of transactions described in the
regulations. (A General License is not a document.)

In the other cases, the shipper or importer can apply for a Specific License.
(A Specific License is a document. It is signed and on U.S. Treasury
Department stationery.)
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U.S.-Sanctioned Countries (and Their Agents)
Include:
Broad





Cuba
Iran
North Korea*
Sudan
Syria
Limited to Specific Individuals








* Imports are prohibited;
exports are permitted.



The Balkans
Belarus
Burma (Myanmar)
Congo, Democratic Republic of
Iraq
Ivory Coast
Liberia
Libya
Russia (Sectoral Sanctions)
Somalia
Zimbabwe
In addition, importation into the U.S. of rough diamonds from any country is
prohibited without certain documentation proving the country of origin.
http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx
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Penalties

Fines: USD50,000.00 to USD1,075,000.00 per count

Criminal Penalties – Up to 20 years in jail

Certain violations, e.g., money laundering, can carry more adverse
consequences

Loss of reputation due to adverse publicity
If a bank participates in a transaction that violates OFAC
regulations and a correspondent bank, freight forwarder, airline,
etc., detects the omission, they are obligated to report that bank
to OFAC.
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What Banks Actually Do

Check the names and addresses of all parties and the routing instructions in
all letters of credit (import, export, standby) against the OFAC lists and
various lists of “bad people,” like the list of Denial Orders, and Politically
Exposed Persons; refuse to issue or advise L/Cs that involve any such
people

Check the names and addresses of all parties and actual routing of goods in
letter of credit documents against the OFAC lists and the lists of “bad
people”

Block both funds and documents if any people or countries from the OFAC
lists show up in the documents
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What Banks Actually Do

Include language of the following sort in transferable letters of credit:
– “This letter of credit may be transferred, however, the name of any proposed
transferee must be provided to us for approval prior to any transfer being effected.”
– “This letter of credit is transferable. Transfer to any parties under this letter of credit
is subject to the United States Office of Foreign Assets Control regulations in force
from time to time.”
This has, however, become problematic…
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Sanctions Clauses Used in Letters of Credit

Were originally used by foreign branches of U.S. banks to remind parties that
they will follow U.S. law and regulations

Are not standardized

Are generally not objectionable when they simply inform the parties

Are objectionable when they give the issuer discretion as to whether or not to
honor

Are objectionable when they are unnecessarily complex
There is no requirement for banks to include sanctions
clauses in L/Cs
The best sanctions clause merely reminds the parties to the
L/C that the bank follows U.N., U.S., etc., sanctions
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Sanctions Clauses Used in Letters of Credit
An example of a simple, informative sanctions clause is:
Presentation of document(s) that are not in compliance with the applicable
anti-boycott, anti-money laundering, anti-terrorism, anti-drug trafficking, and
economic sanctions laws and regulations is not acceptable. Applicable laws
vary depending on the transaction and may include United Nations, United
States, and/or local laws.
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Sanctions Clauses Used in Letters of Credit
An example of a more complex sanctions clause that brings into question
the bank’s obligation is:
[Bank] complies with the international sanctions laws and regulations issued
by the United States of America, the European Union, and the United
Nations (as well as local laws and regulations applicable to the issuing
branch) and in furtherance of those laws and regulations, [Bank] has
adopted policies that in some cases go beyond the requirements of
applicable laws and regulations. Therefore [Bank] undertakes no obligation
to make any payment under, or otherwise to implement, this letter of credit
(including but not limited to processing documents or advising the letter of
credit), if there is involvement by any person (natural, corporate or
governmental) listed in the USA, EU, UN, or local sanctions lists, or any
involvement by or nexus with Cuba, North Korea, Sudan, Iran, or Myanmar,
or any of their governmental agencies.
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U.S. Anti-Boycott Regulations
What Are We Talking About?

Boycotting of countries, individuals, companies, and products

Regulations prohibiting U.S. Persons from participating in another country’s
boycott by:
– Refusing to do business (with blacklisted firms & friendly countries)
– Discriminating (based on race, religion, sex, or national origin)
– Furnishing individual information (about race, etc.)
– Furnishing business information

Public disclosure of participation in a boycott
The point of the anti-boycott regulations is to prevent U.S. entities from
being used as pawns in someone else’s game
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Structure of Boycotts
1. Primary Boycott
Syria refuses to trade with the country of Israel.
Countries are free to boycott one another. U.S. Persons may comply with a
Primary Boycott, by contracting not to ship goods from a boycotted country,
but must report receipt of requests to comply.
Permissible but Reportable
Example: Goods of Israeli origin prohibited
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Structure of Boycotts
2. Secondary Boycott
Syria refuses to trade with anyone who does business with Israel. Syria
develops a “black list” of those trading with Israel.
U.S. Persons may not comply with a request to participate in another
country’s boycotts and must report receipt of requests to comply.
Prohibited and Reportable
Example: Certificate that goods are not of Israeli origin
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Structure of Boycotts
3. Tertiary Boycott
Syria refuses to trade with anyone who does business with those on Syria’s
“black list.”
U.S. Persons may not comply with a request to refuse to do business with
people on a “black list” and must report receipt of such requests.
Prohibited and Reportable
Example: Certificate that the exporter does not do business with companies
on the Saudi Arabian “black list”
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Other Concerns
“White List” A list of companies, etc. that a country is willing to do business
with. Opposite of a “black list” but is considered Reportable and Prohibited.
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Role of Banks…


No bank may issue, pay, honor, confirm, or otherwise “implement” a letter of
credit that contains a condition or requirement, compliance with which would
violate a prohibition of the Export Administration Act.
A bank may, however, advise a beneficiary that there exists a letter of credit
in his favor.
It is not clear whether the bank may deliver a copy of the letter
of credit to the beneficiary before Prohibited language is
deleted.
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Role of Banks…

Review letters of credit and documents

Identify boycott-related language

–
Reportable but not Prohibited
–
Reportable and Prohibited
–
Neither Reportable nor Prohibited
Report findings
Rules & Regulations - Buddy Baker
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Penalties

Fines are imposed by the Department of Commerce.

Fines can be for “implementing” an L/C with Prohibited language, for failing to
report an LC with Reportable language, or for late reporting.

Fines may be for up to USD50,000.00 per violation -- more for repeat
offenders and serious violations.

Criminal penalties maybe sought against individual for up to USD50,000.00
and or up to 5 years in prison.

Companies can also have their export privileges denied.
Rules & Regulations - Buddy Baker
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What Banks Actually Do

Read every export L/C before advising it to catch boycott language; obtain
amendments when necessary before advising and file reports when required

Examine documents presented under export L/Cs for prohibited and
reportable language; refuse documents with prohibited language (get the
language removed); file reports when necessary
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USA PATRIOT Act
What Is Money Laundering?
Money laundering is the process of integrating the proceeds of crime into
the legitimate stream of financial commerce by masking their origin

A process to make illegitimate funds appear legitimate

Seeks to conceal or disguise the existence or source of funds

Facilitates crime by allowing criminals to maintain control over such funds
after they’ve been laundered

Involves more than handling deposits of large amounts of cash – may involve
elaborate systems of loans, wires, purchase and sale of goods, front
companies, and shell banks
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Example 1
Trade price manipulation - sell something for nothing:
Move USD1,000,000 from U.S. drug dealer to foreign drug supplier through
U.S. export at low price
1. U.S. drug dealer has USD1 million cash from street sales to pay to foreign drug
supplier
2. Dealer buys 200 Rolex watches at USD5,000/ea (pays USD1,000,000 cash)
3. Dealer exports watches to foreign supplier at USD5.00 each (receives USD1,000)
4. Foreign supplier sells 200 Rolex watches at USD5,000 each = USD1,000,000
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Example 2
Trade price manipulation - buy nothing for something:
Move USD1,000,000 from U.S. drug dealer to foreign drug supplier through
U.S. import at high price
1. U.S. drug dealer has USD1 million in bank deposits to pay to foreign drug supplier
2. Foreign drug supplier buys 10,000 pencils at equivalent of 10 cents (USD1,000)
locally
3. Foreign drug supplier sells 10,000 pencils to U.S. drug dealer at USD100 each
4. U.S. drug dealer pays USD1,000,000 to foreign drug dealer
Rules & Regulations - Buddy Baker
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Activities That Need Money Laundering

Criminal activities
– Primary objective is financial gain

Terrorism
– Primary objective is to intimidate
a population or to compel a
government to do or abstain from
doing an act

Both terrorism and other
criminal activities must develop:
– Sources of funding
– Means of laundering those funds
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Sources of Terrorist Financing

Some governments sponsor terrorists

Illegal revenue-generating activities
– Kidnapping
– Extortion
– Large-scale smuggling
– Fraud
– Thefts and robberies
– Narcotics trafficking

Income derived from various “legal” activities
– Community solicitation
– Fundraising by charitable or relief organizations
– Donations
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The USA PATRIOT Act, Section 326

Requires banks to establish and maintain Customer Identification Programs
(“CIPs”) for ALL persons seeking to open “accounts”

Applies to federally-regulated financial institutions, including US offices of
foreign banks

Minimum requirement is to obtain and verify
– Name (and birth date for individuals)
– Address
– Tax ID
– …then keep a record
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Penalties

Reputational damage

Supervisory penalties
– Possible loss of banking charter
– Other enforcement actions

Civil monetary penalties

In some cases, criminal
penalties
– Fines
– Jail

Disciplinary action/termination
of employment
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Elements of an AML Compliance Program

A Customer Identification (Know Your Customer)/Enhanced Due Diligence
Program that provides for identification of clients at account opening or
inception of a business relationship and collection/verification of additional
information commensurate with the risk assessment

A process to identify high-risk customers for on-going transaction monitoring
and enhanced due diligence

Procedures to identify and report suspicious transactions to government
authorities
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When Is Customer Identification Required?


Before a “relationship” is established with any new client, anywhere in the
bank, a due-diligence process known as a Customer Identification must be
undertaken
“Relationship” is not defined in the regulations, but can be taken to involve
some formality
– New credit facilities always require approval
– New depositary accounts always require approval
– Repetitive or large transactions may justify approval

“Increased risk” clients require Enhanced Due Diligence (“EDD”)
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Applicability to Global Trade Services
Departments at Banks

Trade transactions, by definition, involve 2 parties
– A bank will not usually deal directly with both parties, but with one party
and the other party’s bank
– For the purposes of KYC, there are 2 potential customers in a trade
transaction, the domestic corporation and the foreign bank

Who is considered the customer depends on the type of transaction

Although the bank must know their own customer, it is not necessary to know
the customer’s customers (or suppliers)
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58
What Banks Actually Do

Make sure a KYC due diligence review has been conducted on the parties
with whom an “account relationship” seems to exist (most banks use the
IFSA guidelines as to what constitutes an account relationship under a letter
of credit)

Decline transactions where no appropriate party can be properly identified
and classified as a desirable relationship

Return and/or report all “suspicious transactions,” e.g., where the value of
the goods seems out of line or the type of goods seems out of character for
the business the buyer and/or seller appear to be in.
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Suspicious Activities
Red Flags for Suspicious Activities

Politically Exposed Persons (“PEPs”)

Individuals who have or have had senior positions of public trust such as
government officials, senior executives of government corporations,
politicians, important political party officials, etc. and their families/close
associates

Examples of PEPs: heads of state, government/cabinet ministers, senior
judges, senior political party functionaries, members of royal families, etc.
Denied Parties

Companies that have had their export privileges revoked or suspended,
making it illegal for them to sell U.S. products to foreign buyers
PEPs and Denied Parties are added by many services to the list of
Specially Designated Nationals so a subscriber can search on all at once.
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66
Suspicious Trade Transactions


The customer engages in transactions that are inconsistent with the customer’s
business strategy or profile (e.g., a steel company that starts dealing in paper
products) or make no economic sense

A customer deviates significantly from its historical pattern of trade activity
(in terms of markets, monetary value, frequency of transactions, volume or
merchandise type)

Transacting parties appear to be affiliated, conduct business out of a residential
address, or provide only a registered agent’s address

Customer that conducts business in jurisdictions that are at higher risk for money
laundering, terrorist financing, or other financial crimes

Customer shipping items to, through, or from higher-money-laundering-risk
jurisdictions including countries identified by the Financial Action Task Force as
“non-cooperative jurisdictions” as regards anti-money laundering regulations
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
Suspicious Trade Transactions

Customers transacting in activities/goods that potentially involve a higher risk of
money laundering and other financial crimes including activities/goods that may
be subject to export/ import restrictions

Obvious over- or underpricing of goods

Obvious misrepresentation of quantity of goods shipped

The payment terms or tenor are inconsistent with the type of goods

Transaction structure and/or shipment terms appear unnecessarily complex or
unusual and designed to obscure the true nature of the transaction

The L/C contains non-standard clauses or phrases or has unusual characteristics

The L/C is frequently significantly amended for extensions, changes to the
beneficiary and/or changes to payment location
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Suspicious Trade Transactions


The transaction appears to involve the use of front or shell companies for the
purpose of hiding the true parties involved

The bank is approached by a previously unknown party whose identity is not
clear, who seems evasive about their identity or connections, or whose
references are not convincing, or payment instructions are changed at the last
minute

Trade-related documentation under an L/C or documentary collection appears
illogical, altered, fraudulent, or certain documentation is absent that would be
expected given the nature of the transaction

Transaction involves obvious dual-use goods
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Questions?
Basel Accords
Requirement
Basel I
Common Equity
Basel II
2013
Basel III
2015
2019
2.0% of RWA
3.5% of RWA
4.5% of RWA
4.5% of RWA
Tier 1 Capital
4.0% of RWA
4.0% of RWA
4.5% of RWA
6.0% of RWA
6.0% of RWA
Total Capital
8.0% of RWA
8.0% of RWA
8.0% of RWA
8.0% of RWA
8.0% of RWA
-0-
-0-
+2.5% of RWA
Capital Conversion Buffer
Under Basel I, confirmation of a commercial letter of credit has+Upa to 2.5% of RWA
capital requirement of 0.32%
Additional Loss Absorbency
+1% to 2.5% of RWA
Counter Cyclical Buffer
Under Basel III, it can be as high as 23.25%
Leverage
(based on Tier 1 Capital)
(based on Total Capital)
Observation
Observation
3% of direct and
contingent assets
(4% of direct assets)
Liquidity Coverage
Observation
21 days
21 days
(30 days)on Capital
(30 days)
Banks will need to charge 4.2% per annum to get a Return
Net Stable Funding
Observation
Observation
of 18% and 72 times as much to get the same
Return on
Capital as 1 year
before!
 The amount
of Risk-Weighted Assets (“RWA”) is computed by multiplying the amount of each asset and contingent asset by a risk weighting and a Credit Conversion




Factor (“CCF”)
 Under Basel I, risk weightings are set: 0% for sovereigns, 20% for banks where tenors ≤ one year, 50% for municipalities and residential mortgages, 100% for all
corporate obligors
 Under Basel II, risk weightings are based on internal or external (rating agency) risk ratings with no special distinction for banks; capital requirements for
exposures to banks are increased by as much as 650% (from 20% to as much as 150%)
 The Credit Conversion Factor for Letters of Credit varies under Basel I vs. Basel II and Basel III
 Under Basel I, this is 20% for commercial L/Cs, 50% for performance standbys and 100% for financial standbys; confirmation of a commercial letter of credit
has a capital requirement of 0.32% (8% x 20% x 20%)
 Under Basel II and III, “Sophisticated Banks” are required to do a statistical analysis of losses based on structure (and, due to limited losses, there are
insufficient loss data for any bank in the world to do this for letters of credit, resulting in using the default CCF of 100%; under Basel II, the capital requirement
to confirm a letter of credit can jump from 0.32% to 12%, viz., 8% x 150% x 100%; under Basel III, it can be as high as 23.25%, viz., 15.5% x 150% x 100%)
In the US, Basel II only applies to “Large, Internationally-Active Banks”--the 9 largest commercial banks fit the definition; as of January 1, 2013, Basel III applicability has
not been finalized, but is proposed to remain the same
The Leverage ratio does NOT apply risk weightings or credit conversion factors; the ratio is 100% for all direct and contingent assets except performance-based
standbys (50%) and commercial L/Cs (20%)
The Additional Loss Absorbency requirement applies only to “Globally Systemically Important Banks”
Depending on the bank and the point in the economic cycle, under Basel III, the total capital requirement for a bank in 2019 may be as much as 15.5% of Risk-Weighted
Assets (“RWA”), compared with 8% under Basel I and Basel II
The Impact on Exporters of the
Rules & Regulations Governing Banks
That Provide Trade Services
Buddy Baker
[email protected]
(312) 704-6942
Rules & Regulations
Governing Trade Services