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#1216747 - 07/13/09 09:13 PM Special Measures Section 311
TMichelle Offline
100 Club
Joined: Jan 2009
Posts: 106
I am trying to add a section to our policy on Special Measures Section 311 per our a previous auditors suggestion. Can someone tell me their process for this at their bank? I am not sure i understand this...

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#1216851 - 07/14/09 01:14 PM Re: Special Measures Section 311 TMichelle
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
The examiners tried to get me on this one, too. They thought that since we did foreign wires, we should be screening the 311 list. I read through the requirements and then studied the handful of the special measures that were effective. I showed them that in each case, the only special measure that was imposed was the fifth one having to do with foreign correspondent or payable through accounts, which we don't have. They agreed, but to appease them, I added this to my procedures.

SPECIAL MEASURES

Section 311 of the USA PATRIOT Act added 31 USC 5318A to the BSA, which authorizes the Secretary of the Treasury to require domestic financial institutions to take certain special measures against foreign jurisdictions, foreign financial institutions, classes of international transactions, or types of accounts of primary money laundering concern. Section 311 provides the Secretary of the Treasury with a range of options that can be adapted to target specific money laundering and terrorist financing concerns.

The following five special measures can be imposed, either individually, jointly, or in any combination:

1. Recordkeeping and Reporting of Certain Financial Transactions

2. Information Relating to Beneficial Ownership

3. Information Relating to Certain Payable Through Accounts

4. Information Relating to Certain Correspondent Accounts

5. Prohibitions or Conditions on Opening or Maintaining Certain Correspondent or Payable Through Accounts

The BSA Officer will request to receive notification by e-mail when Section 311 – Special Measures are updated on FinCEN’s website. Each time the list is updated, a review of the special measures will be performed to identify any special measures that may apply to the Bank.

Section 311 - Special Measures
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1216860 - 07/14/09 01:29 PM Re: Special Measures Section 311 Kelsey D
TMichelle Offline
100 Club
Joined: Jan 2009
Posts: 106
Thanks Kelsey,
Thats exactly what i needed to know!

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#1216891 - 07/14/09 02:18 PM Re: Special Measures Section 311 TMichelle
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
You're welcome!
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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