Control List Issued -- Institutions Must Designate Senior Individual
The bank regulatory agencies and the NCUA have just released a "Joint Agency Request Relating to Information Pertaining to the Terrorist Attacks". In it, they spell out the following:
- A unified list of individuals and entities that have been identified by the FBI and other agencies -- referred to as the Control List -- will be released to financial institutions.
- The Control List is confidential and should only be circulated to individuals within your institution on a need to know basis. It should not be disseminated to anyone outside your institution. Confidentiality is crucial!
- The regulators will send institutions a copy of the list via email. You must provide the name, title, telephone number and email address of a senior-level individual within your institution that you have chosen as the point person for this information. This should be a person "who appreciates the sensitive nature of the investigation and will exercise appropriate discretion". Follow the instructions on the cover letter you receive from your regulator to submit the point person's contact information.
- Your institution will not receive a copy of the Control List until you submit the point person's information and email address. This should be done no later than October 12, 2001.
- Once you receive the Control List, they ask that you check your records to determine whether any of the individuals or entities on the Control List have or have had any transactions or relationships with your institution in the U.S. or elsewhere.
- If you identify any transaction or relationship with any of the individuals or entities, they ask that you promptly send an email message to firstname.lastname@example.org
- Indicate in the email only that you have a positive response. The information will then be given to law enforcement authorities for them to obtain a supoena to be served on your institution for relevant records.
- In addition, you are reminded to report any suspicious activity related to any of the names on the Control List by filing a Suspicious Activity Report and by contacting the FinCEN hotline at 1-866-556-3974
First published on 01/01/2000