"Know Your Customer" Guidance in the Wake of Russian Money Laundering Scandals
In August of this past year it was learned that $7 to $15 billion, a large portion of which allegedly originated from organized crime, had been moved out of Russia through the Bank of New York and promptly rerouted to accounts around the world. Against this background, on September 23, 1999, the Department of the Treasury and the Department of Justice announced the "1999 U.S. National Money Laundering Strategy" setting forth a number of new regulatory initiatives, and several key anti-money laundering bills were introduced during this past session of Congress. Despite renewed focus on the importance of anti-money laundering efforts, the rules and proposals arising from a concept central to these efforts,"Know Your Customer," have been in flux. Moreover, "Know Your Customer" principles may now be subject to some uncertainty given the recent attention to consumer privacy concerns in connection with the
