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Expanded Guidance on Customer Identification Program Rules Issued Pursuant to the USA PATRIOT Act
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May 3, 2005
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| Circular No. 11702 | |
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To All Depository Institutions and Others In a supervisory letter (SR-05-9) dated April 28, 2005, the federal bank, thrift regulatory bodies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the Agencies) have released an expanded frequently asked questions documents (FAQs) to provide additional guidance on the customer identification program rules issued under section 326 of the USA PATRIOT Act. The expanded FAQs incorporate the FAQs previously released by the Agencies in 2004. The expanded interpretive guidance addresses the applicability of the customer identification rules to data processing activities, to bank holding companies and their non-bank subsidiaries, and to subsidiaries of banks. The FAQs also provide additional guidance on the definitions of "account," "bank," and "customer."
Robert A. Otero William L. Rutledge
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