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New PATRIOT Act deadlines approach for broker‐dealers: Customer identification programs to be implemented by October 1, 2003

Betty Santangelo (Partner, Schulte Roth & Zabel LLP, New York, NY, USA; Betty.Santangelo@srz.com)
Margaret Jacobs (Associate, Schulte Roth & Zabel LLP, New York, NY, USA; Margaret.Jacobs@srz.com)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 1 April 2003

83

Abstract

The anti‐money‐laundering provisions of the USA Patriot Act of 2001 (the “Patriot Act”) continue to cause a profound transformation in the way the United States investment industry conducts its business. Over the past year under the authority of the Patriot Act, which amended the Bank Secrecy Act (“BSA”), the United States Department of Treasury (“Treasury”) and the relevant federal regulators have issued rules requiring a broad range of compliance mechanisms, including: the establishment of anti‐money‐laundering (“AML”) programs; the filing of suspicious activity reports; the prohibition against providing financial services to foreign shell banks (i.e., banks without physical locations); the maintenance of records with respect to accounts for foreign banks; and the sharing of transactional information among financial institutions and between financial institutions and law enforcement.

Keywords

Citation

Santangelo, B. and Jacobs, M. (2003), "New PATRIOT Act deadlines approach for broker‐dealers: Customer identification programs to be implemented by October 1, 2003", Journal of Investment Compliance, Vol. 4 No. 2, pp. 45-53. https://doi.org/10.1108/15285810310813059

Publisher

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MCB UP Ltd

Copyright © 2003, MCB UP Limited

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