Evolving regulation—from the Bank Secrecy Act through the USA Patriot Act: who are your customers, what are they doing, and why should you care?

RMA Journal, The, July-August, 2004 by Michael I. Frachioni

Conclusion

In short, the Bank Secrecy Act and USA Patriot Act require institutions to adopt and implement comprehensive, written compliance programs to address money laundering and other financial crimes. These programs must include comprehensive, ongoing, and up-to-date training for all relative personnel, provisions for periodic internal or external audits of activities under the program, and complete and thorough record keeping of all currency transactions, suspicious activities, and other required reports.

The scrutiny of such programs and the activities they are meant to prevent will not soon wane. Bankers should take all necessary steps to avoid the harsh regulatory penalties and risk to reputation that may follow noncompliance.

Michael Frachioni may be contacted by e-mail at mfrachioni@dkwlaw.com.

[c] 2004 by RMA. Michael Frachioni, a member of the Pennsylvania and New York bars, is a member of DKW Law Group, LLC, and a principal of FiCap Strategic Partners, LLC< consultants to financial institutions nationwide.