USA PATRIOT Act Update Memorandum: U.S. Treasury Releases ...

The Interim Final Rule and its commentary indicate that the application of the antimoney
laundering rules are not likely to be uniform but instead are likely to be tailored to
each industry. As such, the hedge fund industry should view this release as an
encouraging sign that the U.S. Treasury is willing to listen to the concerns of financial
institutions. Therefore, the hedge fund industry should be pro-active when proposed rules
for hedge funds are released for comment and collaborate with the U.S. Treasury on how
anti-money laundering should be accomplished in the industry.
* * * * * * *
If you have any questions or comments regarding compliance with the USA PATRIOT
Act and about the U.S. Treasury’s press release and the accompanying Interim Final Rule
implementing Section 312 of the USA PATRIOT Act, please feel free to contact Michael
G. Tannenbaum at (212) 508-6701, Ricardo W. Davidovich at (212) 508-6710 or
Roderick J. Cruz at (212) 702-3149.
July 30, 2002
[668425-2]
6