There are no actual requirements in the section 326 of the statute itself. There are minimum requirements for the regulations, but the section doesn't require that financial institutions do anything. The statute requires the Secretary of the Treasury to "prescribe regulations setting forth the minimum standards..." [Section 326(a)(1)(1)]

Until there is a final rule published and effective, there can be no violation of regulation. I don't see how we can violate the statute either, since it doesnt require us to do anything. IMHO, making changes to existing procedures is premature. I think planning for changes is a good idea, however.

AS to effective date, the statute literally says "Final regulations prescribed under this section shall take effect before the one-year period beginning on the date of enactment of the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001." [Section 326(a)(6)] Literally, the Treasury can (and probably must) make the final rule effective October 25, the last day before the expiration of the 1-year period from date of enactment.

However, "effective" is not necessarily "mandatory compliance." Treasury can delay the date we must comply with the new rules. The regulatory agencies delay mandatory compliance with rules all the time. Certainly, many of us included requirests for delays in the effective date of the rules. I think the indication is that there will be some delay.
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The opinions expressed here are personal and do not represent opinions of my employer.