Joint Trades to FinCEN on Anti-Money Laundering Special Due Diligence Programs

The Securities Industry Association (SIA)*, The Bond Market Association (TBMA)*, the ABA Securities Association, The American Bankers Association, the Bankers’ Association of 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 Clearing House Association, L.L.C. (the Associations) provide comments to the Financial Crimes Enforcement Network (FinCEN) on anti-money laundering (AML) special due diligence programs for certain foreign accounts, Regulatory Information Number 1506-AA29.  The U.S. Department of Treasury and FinCEN issued the proposal relating to the implementation of Section 312 of the USA PATRIOT Act that require enhanced due diligence for correspondent accounts established, maintained, administered or managed for certain types of foreign banks.  The Associations’ address: 1) the general risk-based approach to enhanced due diligence embodied in the proposal; 2) the risk-based approach to applying the specific elements of enhanced due diligence; 3) the use of the term “nest banks”; and 4) the estimation of regulatory burden set forth in the proposal.

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