Joint Trades to FinCEN on AML Due-Diligence Programs for Certain Foreign Accounts

The Securities Industry Association (SIA)*, The Bond Market Association (TBMA)*, the ABA Securities Association, the American Bankers Association, the Bankers Association for Finance and Trade, the Financial Services Roundtable, the Futures Industry Association, the Institute of International Bankers, the Investment Company Institute, the Swiss Bankers Association, and the New York Clearing House Association L.L.C provide comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury on proposed rulemaking to implement Section 312 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.  The proposed rulemaking relates to anti-money laundering due diligence programs for certain foreign accounts. The groups submit that an approach which does not permit the covered financial institution to differentiate meaningfully among customers, accounts and transactions will result in less rather than more effective deterrence and prevention.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.