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Important Dates:
By April 24, 2002 - every financial institution is required to
have adopted policies, procedures and controls to detect and prevent money
laundering.
By July 23, 2002
- every financial institution is required to
have adopted special due diligence procedures for correspondent
accounts and private banking accounts maintained by non-U.S.
persons.
By October 26, 2002
- every financial institution is required to have implemented "know
your customer" procedures for opening customers accounts.
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THE UNITING AND STRENGTHENING
AMERICA BY PROVIDING APPROPRIATE TOOLS REQUIRED TO INTERCEPT AND OBSTRUCT
TERRORISM ACT OF 2001- The USA Patriot Act (the "Act")- was
signed on October 26, 2001 to amend the Bank Secrecy Act and other legislation
to require that financial institutions establish anti-money laundering
programs which are intended to fight terrorism and other criminal activities.
The Act places new or additional
requirements on financial institutions. Some of the new requirements include:
- Having appropriate controls reasonably designed to detect and report
instances of money laundering
- Ensuring that U.S.
correspondent accounts for foreign banks are not used to indirectly
provide banking services to foreign "shell" banks- banks that have no
physical presence in any country
- Identifying accounts
maintained by senior foreign political figures, their immediate families
or close associates
- Establishing
procedures for identifying customers opening accounts, including procedures
to verify customer identity and maintaining records of information used
to verify identity
- Designating a compliance
officer, conducting ongoing employee training and establishing an independent
auditing function to test the anti-money laundering programs in place
Financial
Institutions and the USA Patriot Act
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