STEP Bahamas Branch and the AIBT USA PATRIOT ACT

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SEC 312 Enhanced Due Diligence Required for: - Correspondent Accounts - Private banking accounts - aggregate of $1 million - managed by a client relationship officer - established by one or more direct or beneficial owners Treasury Department Interim Final Rules issued May 23rd, 2002.- Enforces provisions for all Private banking accounts (including accounts at broker dealers) but only in force re: Correspondent Accounts at Banks STEP Bahamas & the AIBT September 26th, 2002 27
Correspondent Accounts: (Banks only) Pending Final Rules U.S. Financial Institutions must establish due diligence policies, procedures and controls reasonably designed to detect and report money laundering through correspondent accounts established, maintained, administered or managed in the U.S. for a foreign financial institution: Regulations Target “high risk accounts” STEP Bahamas & the AIBT September 26th, 2002 28
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 and 26: Physical Presence means a place of
Page 27: What is a Correspondent Account?
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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