Compliance officers are calling it "regulation through examination." The Annunzio-Wiley Anti-Money Laundering Act of 1992 gave Treasury the authority to promulgate a know-your-customer rule.

Such a rule has yet to materialize. Nevertheless, U.S. branches and agencies of foreign banks and Edge Act corporations that engage in private banking are confronted by regulators who are enforcing their own variation of a know-your-customer standard.

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