USA Patriot Act - Extension of Applicability Dates for Implementing International Correspondent Banking Provisions and Private Banking Provisions of Section 312

Bank Secrecy Act (BSA)
Patriot ActFederal Deposit Insurance Corporation (FDIC)
Financial Crimes Enforcement Network (FINCEN)Anti-Money Laundering

Summary: The Financial Crimes Enforcement Network (FinCEN) has issued the attached final rule extending, in part, the applicability dates for implementing the international correspondent banking provisions and the private banking provisions of Section 312 of the USA PATRIOT Act.

Highlights:

On January 4, 2006, FinCEN issued a final regulation implementing Section 312 of the USA PATRIOT Act. The final rule took effect on February 3, 2006, and superseded the interim final rule issued on July 23, 2002.

The final rule requires U.S. financial institutions to apply due diligence to correspondent accounts maintained for certain foreign financial institutions and private banking accounts maintained for foreign individuals.

Regarding correspondent banking, generally, the rule establishes the scope of U.S. financial institutions to which the rule applies and outlines general due diligence requirements to mitigate exposure to potential money-laundering activities.

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