SIA and FIA Submit Supplemental Comments to FinCEN on Special Due Diligence Programs for Certain Foreign Accounts
The Securities Industry Association (SIA)* and the Futures Industry Association (FIA)provide comments toFinancial Crimes Enforcement Network (FinCEN)on special due diligence programs for certain foreign accounts under Section 312 of the USA Patriot Act, Final 312 Rule.The Associations send a follow-up to their letter of February 23, whichrequested an extension to implement the rule. This second letter expands on the need for more time and fully describes the issues that the Associations are requesting that FinCEN address through guidance.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.