Treasury Issues New Rules and ProposalsFor The PATRIOT ACT

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WASHINGTON - (12/29/05) The Treasury Dept. issued final andproposed rules under Section 312 of the USA PATRIOT Act setting duediligence requirements for financial institutions, including creditunions, that have any types of off-shore account activity. Section312 applies due diligence requirements to U.S. institutions thatestablish, maintain, administer or manage a correspondent accountor private account in the U.S. for a non-U.S. person. The finalrule, released last week, implements all of Section 312 except the“enhanced” due diligence. The latter is addressed inthe proposed rule, which seeks to clarify the flexibility financialinstitutions have in applying their enhanced due diligenceprocedures on a risk-assessed basis. The comment period is 60days.

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