I'm lost. Do we have regulations implementing the Patriot Act? Was there a conclusion as to whether we have to have a separate AML Policy or can it be incorporated into an existing BSA Policy? What about the Proposed Rule on Information Sharing - do we have a final rule?

We have some regulations from USA PATRIOT with more to come. You need an AML policy, but it doesn't have to contain anything more than BSA required. The information sharing regulations are in interim final form for sharing between financial institutions (they may still change because they were also issued as a proposal) and are still in proposed form for sharing with law enforcement.