STEP Bahamas Branch and the AIBT USA PATRIOT ACT

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Correspondent Accounts Ownership of Foreign Banks Covered Financial Institutions must maintain records identifying owners of accounts held for a foreign bank Dept. of Treasury Rule issued September 18th, 2002 (superceding Interim rule issued on December 28th, 2001) - provides safe harbor certification: U.S. Banks must maintain records of: • Owners of foreign banks • Agent in the U.S. designated to accept service of process for records regarding the correspondent account - covers all records within and outside the U.S. Secretary of Treasury and Attorney General may issue summons or supboenas on any foreign bank that mantains a correspondent account in the U.S. requesting records relating to such accounts and funds deposited within the account. STEP Bahamas & the AIBT September 26th, 2002 25
What is a Correspondent Account? “a correspondent account is an account established by a covered financial institution for a foreign bank to receive deposits from, to make payments or other disbursements on behalf of a foreign bank or to handle other financial transactions related to the foreign bank.” (Final Rule Issued September 18th, 2002) U.S. Treasury Department Final Rule Issued September 18th, 2002 This appears to effect every account held by a foreign bank. STEP Bahamas & the AIBT September 26th, 2002 26
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 and 18: Is the Act in Force? Certain Provis
Page 19 and 20: What is a Financial Institution?
Page 21 and 22: U.S. Financial Institutions Certain
Page 23 and 24: Main Provisions • Sec. 313. Shell
Page 25: Physical Presence means a place of
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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