Letters

SIA and FIA Submit Comments to FinCEN on Special Due Diligence Programs for Certain Foreign Accounts

Summary

The Securities Industry Association (SIA)* and the Futures Industry Association (FIA) provides comments (First Letter) to the Financial Crimes Enforcement Network (FinCEN) on anti-money laundering and compliance with the USA PATRIOT Act (the Act).  The Associations are having difficulty implementing the Final Rule for Section 312 of the Act, which requires due diligence for correspondent accounts and for private banking accounts for non-U.S. persons.  The Associations detail significant practical concerns and the need for additional guidance on certain issues.

*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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