Due Diligence Programs for Certain Foreign Accounts
July 24, 2002
Circular No. 11455

To All Depository Institutions and Others Concerned in the Second Federal Reserve District:

In a Federal Register notice, the Department of the Treasury and the Financial Crimes Enforcement Network announce an interim final rule, effective July 23, 2002, regarding section 312 of the USA PATRIOT Act of 2001. Section 312 requires U.S. financial institutions to establish due diligence policies, procedures, and controls reasonably designed to detect and report money laundering through correspondent accounts and private banking accounts that U.S. financial institutions establish or maintain for non-U.S. persons. Comments on the interim final rule are due August 22, 2002.

A Federal Reserve Supervisory Letter on the matter is attached.

Questions on this matter may be directed, at this Bank, to Nicholas Farco, Examining Officer, Legal and Compliance Risk Department.