Get out the stopwatch! If your institution receives a request from your federal regulator for information relating to your anti-money laundering compliance or relating to a customer of your institution, the countdown clock starts ticking from the moment you receive the request. Under Section 319 of the USA PATRIOT Act, you must comply with the request within 120 hours after receiving it. Specifically, you must provide information and account documentation for any account opened, maintained, administered or managed in the United States by your institution that is covered by the request, as well as any information requested relating to your anti-money laundering compliance.
Designate a central person as the point person on records requests, as well as one or more back-up persons.
Make sure everyone at your institution who interfaces with the regulators is aware of this new timing requirement and understands the importance of routing all requests to the designated officer.
Note the date and time you receive the request on the request itself so you can document your compliance with the 120 hour rule.
Notify the regulator immediately if you anticipate any delays.
The original version appeared in the October 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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