STEP Bahamas Branch and the AIBT USA PATRIOT ACT

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SEC 326 SEC Rules 7 Risk factors: - Broker Dealer’s Size - Location - Method by which customers open accounts - Type of Accounts - Types of Transactions - Customer base - Reliance on another broker dealer (ie. introducing broker-clearing agent) Questions: What is an Account? Who is a Customer? STEP Bahamas & the AIBT September 26th, 2002 31
SEC 314 Information Sharing Financial Institutions may share information with each other if they have suspicions of money laundering or terrorist financing. Requires annual electronic filing with FINCEN Erodes protections afforded under the Right to Financial Privacy Act and Gramm-Leach-Bliley Act STEP Bahamas & the AIBT September 26th, 2002 32
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 and 28: What is a Correspondent Account?
Page 29 and 30: Correspondent Accounts: (Banks only
Page 31: SEC 326 Account Verification Proced
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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