Treasury Issues Rules Concerning Anti-Money Laundering Programs. Mutual Funds Must Establish Programs by July 24, 2002. Other Types of Investment Companies Granted Temporary Exemption That Will Not Extend Beyond October 24, 2002
The Financial Crimes Enforcement Network of the U.S. Department of Treasury ("FinCEN") issued a series of four interim final rules ("AML Rules"), implementing Section 352 of the USA PATRIOT Act ("Section 352"). Section 352 requires that "financial institutions," as defined under the federal Bank Secrecy Act ("BSA"), establish anti-money laundering programs ("AML Programs"). An AML Program must include, at a minimum (1) the establishment of internal policies, procedures, and controls; (2) the designation of a compliance officer; (3) an ongoing employee training program; and (4) an independent audit function to test programs. The AML Rules will take effect as of April 24, 2002, but are still subject to public comment. Comments are to be received by no later
