The Financial Crimes Enforcement Network (FinCEN) has issued interpretive guidance to clarify the due diligence obligations of executing dealers in over-the-counter foreign exchange and derivatives markets pursuant to prime brokerage arrangements under the correspondent account provisions of the USA PATRIOT Act. The correspondent account rule applies to correspondent accounts that are established, maintained, administered or managed by a covered financial institution for a foreign financial institution. The guidance indicates that FinCEN does not view the interaction between an executing dealer and a prime brokerage client as the establishment, maintenance, administration or management of a correspondent account for the prime brokerage client that would require an executing dealer to comply with the due diligence provisions of the correspondent account rule.