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October 28, 2002
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InfoBytes Special AlertConsumer Finance Headlines &
Deadlines of Interest to our Clients and Friends
Treasury Postpones Effective Date of USA PATRIOT Anti-Money
Laundering Program Requirement For Certain Types of Financial
InstitutionsOn October 25, the Financial Crimes Enforcement Network
of the Treasury
Department (FinCEN) indefinitely postponed the effective date of
Section 352 of
the USA PATRIOT Act (which requires all financial institutions
covered by theBank Secrecy Act to institute an anti-money
laundering program) for certain
financial institutions including loan and finance companies.
In rules published in April, implementing the anti-money
laundering program
requirement for banks, securities broker/dealers and certain
other financial
institutions, FinCEN deferred the effective date of Section 352
for other financial
institutions until October 26. The October 25 release extends
the deferral untilrules specifically require these other categories
of financial institution to implement
an anti-money laundering program. This deferral applies to all
of the following
financial institutions: dealers in precious stones, metals or
jewels; pawnbrokers;loan or finance companies; private bankers;
insurance companies; travel agencies;
telegraph companies; sellers of vehicles, including automobiles,
airplanes and
boats; persons engaged in real estate closings and settlements;
investmentcompanies other than open-end mutual funds; commodity
pool operators; and
commodity trading advisors.
FinCEN's release notes that it intends to propose rules on
anti-money launderingprograms for all of these other financial
institutions within six months. The release
notes that proposed rules for financial institution including
insurance companies
and investment companies have already been published. It does
not state whetherfinal rules for insurance companies and investment
companies will be issued before
new proposed rules are issued for the other categories of
financial institutions.
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The release is available at
http://www.ustreas.gov/press/releases/po3580.htm. If
you have any additional questions, please contact Jacob Thiessen
[email protected].
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