Developments of Note
Department of Treasury Issues Interim Guidance Concerning Anti-Money Laundering Compliance Related to Correspondent Accounts for Foreign Banks
The Department of the Treasury ("Treasury") issued interim guidelines (the "Guidelines") designed to assist U.S. financial institutions’ efforts to comply with two anti-money laundering provisions of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the "USA Patriot Act"). The USA Patriot Act was enacted on October 26, 2001 and its anti-money laundering provisions were summarized in a November 2, 2001 special issue of the Alert. The Guidelines answer a number of questions raised by sections 31 U.S.C. 5318(j) and (k), added by the USA Patriot Act. These two provisions become effective on December 25, 2001, but Treasury expects that affected entities will "promptly" implement the Guidelines concerning these provisions.
