*Letters

SIA Submits Comments to FinCEN on Implementing Provisions of the USA PATRIOT Act

Published on:
January 1, 2001

The Securities Industry Association (SIA)* provides comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S.Department of the Treasuryon aninterim rule 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.Section 312 of the USA PATRIOT Act requires U.S.financial institutions, such as broker-dealers, banks and mutual funds, to establish due diligence policies to detect money laundering through correspondent accounts with foreign financial institutions and private banking account with foreign persons. SIA remains concerned about the private banking account requirements, which continue in force in the interim rule for broker-dealers, banks and futures commission merchants (FCMs).

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

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