STEP Bahamas Branch and the AIBT USA PATRIOT ACT

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Summary- What has changed? U.S. Patriot Act requires ALL Financial Institutions to: • Establish Anti-Money Laundering Programs • Development of Internal Policies, Procedures and Controls • Designation of Compliance Officer • Ongoing employee training programs • Independent audit function to test programs • File Currency Transaction Reports • File suspicious Activity Reports with FINCEN (Financial Crime Enforcement Network) • Comply with Regulations regarding Account Documentation and ID Verification • Extends Money Laundering Offenses and Reach of U.S. Law Enforcement STEP Bahamas & the AIBT September 26th, 2002 17
What is a Financial Institution? •Foreign Banks •U.S. Financial Institutions •Covered Financial Institutions STEP Bahamas & the AIBT September 26th, 2002 18
Page 1 and 2: STEP Bahamas Branch and the AIBT US
Page 3 and 4: USA Patriot Act of 2001 Uniting and
Page 5 and 6: Terrorism:September 11th, 2001 STEP
Page 7 and 8: Tax Evasion: $70 Billion in Lost Ta
Page 9 and 10: Prior to the Patriot Act • No lev
Page 11 and 12: Prior Unsuccessful Attempts to Pass
Page 13 and 14: Know Your Customer • KYC is Reall
Page 15 and 16: Gatekeeper STEP Bahamas & the AIBT
Page 17: Is the Act in Force? Certain Provis
Page 21 and 22: U.S. Financial Institutions Certain
Page 23 and 24: Main Provisions • Sec. 313. Shell
Page 25 and 26: Physical Presence means a place of
Page 27 and 28: What is a Correspondent Account?
Page 29 and 30: Correspondent Accounts: (Banks only
Page 31 and 32: SEC 326 Account Verification Proced
Page 33 and 34: SEC 314 Information Sharing Financi
Page 35 and 36: Enforcement:SEC 319 Forfeiture of F
Page 37 and 38: Patriot Act adds three more foreign
Page 39 and 40: Future Developments Anticipated Und
Page 41 and 42: SEC 325 Omnibus Accounts: Secretary

STEP Bahamas Branch and the AIBT USA PATRIOT ACT

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