TCH signed on to a letter to FinCEN with the ABA regarding the proposal to impose special measures against Banca Privada d’Andorra (BPA). The Director proposed to use the “fifth special measure” that authorizes FinCEN to identify direct correspondent accounts for BPA and requires all covered financial institutions to apply commercially reasonable measures to determine whether any existing or prospective customer is a branch, office or subsidiary of BPA. These institutions would be expected to apply increased due diligence to all foreign correspondent accounts initiated through BPA.