Does anyone know where I can obtain a copy of the Patriot Act?

Pat Field
First Arizona Savings

Search on HR 3162, Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism at http://thomas.loc.gov/ .

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

FYI, the new KYC provisions are in Sec. 326. Also, Sec 352 lays out requirements for formal anti-money laundering programs in banks (i.e. an "AML Officer"). And take a look at Sec 365 while you're at it. Whoa! It requires any US "trade or business" to do currency transaction reporting! (Should make all you BSA experts a very valuable commodity to the outside world!) I'm still digging to find when the reg changes must be effective. I understand the banking trade organizations are already providing input on the first swing at the draft regs.

[This message has been edited by Ken Holmes (edited 11-27-2001).]

Ken, you've been spending some proactive time on this, I see. Under 326 there will be regulations effective within a year. And yes, I know the ABA is working on this now starting with 326.

"(6) EFFECTIVE DATE.—Final regulations prescribed under this subsection shall take effect before the end of the 1-year period beginning on the date of enactment of the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001.’".

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

If the Treasury is as fast getting these regs out as they have been in getting out other required regs, I will not hold my breath waiting!

In the November issue of "Money Laundering Alert" there is a great table listing the various sections of the Patriot Act that will require changes to BSA and what those changes are.

Treasury has already published interim guidelines for the foreign shell bank and correspondent certifications in Sections 313 and 319 of the Act. They were published 11/20/2001. Here is the link to the press release:

http://www.treas.gov/press/releases/po813.htm

Congress specified widely varying deadlines for the regulatory requirements of the USA PATRIOT act: 60 days for sections 313 and 319; 120 days for section 314; 180 days for sections 312 and 352; one year for section 326; and an unspecified time for section 325. Staying on top of all this will be a challenge.

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This is a personal observation that should not be taken as legal advice nor relied upon for any purpose.

This from the ABA:

The Federal Reserve sent examiners and the institutions it supervises a letter briefly describing the money laundering provisions in the new anti-terrorism law. "All banking organizations...should ensure that their compliance staffs carefully review the act and prepare to implement its provisions within appropriate time frames," the letter said. While the law does not immediately impose any new filing or reporting obligations, it does require certain additional due diligence and record keeping practices. The letter describes provisions that take effect without new regulations, and other provisions that will require further rulemaking. To read the Fed's SR 01-29, go to http://www.federalreserve.gov/BoardDocs/SRLetters/2001/sr0129.htm

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Jim Bedsole, CRCM, CBA, CFSA

Opinions expressed are my own, and do not necessarily reflect those of my employer.