The Securities Industry Association (SIA)* provides comments to the U.S. Department of Treasury on counter money laundering requirements for correspondent accounts for foreign shell banks; and recordkeeping and termination of correspondent accounts for foreign banks.  The proposals were issued with respect to sections 313 and 319(b) of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001, adding new anti-money laundering sections of the Bank Secrecy Act.  Notwithstanding SIA’s support of the goals of the USA PATRIOT Act, SIA notes that due to the USA PATRIOT Act’s swift passage many of its key elements require greater clarity.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.