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V O U M wf nmmi I T R i t o u M t

FBI to build data warehouseInvestigative data mining part of broadinitiative to fight terrorismBY William MatthewsJune 3, 2002 Printing? Use thisversion.

Email this to a friend.The FBI has selected "investigative datawarehousing" as a key technology to use in thew ar against terrorism.The technique uses data mining and analyticalsof tw are to comb vast amounts of digitalinformation to discover patterns andrelationships that indicate criminal activity. Thesame technology is widely used in thecommercial sector to track consumer activityand even predict consumer behavior.The FBI plans to build a data warehouse thatreceives information f rom multiple FBIdatabases, according to Mark Tanner, theagency's information resources manager.Eventually, the warehouse might receive datafrom other law enforcement and intelligenceagencies.

RELATED LINKSSidebar: "Carnivorebites off too much""Guidelines open data.Web toFBI" [FCW.com, June3, 2002]"FBI counting on IT vs.terrorism" [FederalComputer Week, May20, 2002]"Data-sharing projectsgainmomentum" [FederalComputer Week, March4, 2002]

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Symantec.Data mining and data warehousing are part of amuch larger FBI plan to acquire and employmodern information technology to thwart future terrorist attacks."New technologies are required to support new and different operationalpractices," FBI Director Robert Mueller said May 29, detailing a sweepingoverhaul planned for the federal law enforcement bureau.By the end of the summer, the FBI hopes to hire 900 new agents, includingcomputer scientists and other IT specialists. The bureau overhaul alsoincludes:

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COMPLIANCEHEADQUARTERSFinCEN and the Section 314(a)Information Sharing ProcessSu e Burt, Senior Attorney - Bankers Systems Inc.December 2002

OverviewRecently, the federal regulators shed new light on the section 314(a)information sharing process and the FBI Control List. In a Joint AgencyNotice dated November 26, 2002, the regulators announced thediscontinuation of the Control List and unveiled a new process forhandling information requests from the government. This new processhas been established by FinCEN pursuant to Section 314(a) of the USAPATRIOT Act and will replace the Control List.

This article will discuss the new section 314(a) information sharingprocess and will explain what your financial institution must do to comply.History 101In order to better understand where we are headed with respect togovernment list searches and information sharing, it is helpful toappreciate where we have been.October 2001: In response to the September 11, 2001, attacks, the FBIcreated a confidential document called the Control List. The List wascompiled byvarious federal law enforcement agencies conductinginvestigations into terrorist activities and consisted of names andidentifying data of individuals and entities that these agencies believedmay be related to their investigation. In October of 2001, the FBI providedthe Control List to all financial institution regulators. The regulators, inturn, forwarded the List to financial institutions under their supervisiononce the financial institution had "registered" with its respective regulator.Financial institutions were given until October 12, 2001, to provide theirregulator with the name of a senior level person as the contact for theControl List, that person's title, telephone number, and e-mail address.Upon receipt of this registration information, the regulators e-mailed acopy of the Control List to the institution.October 26,2001: The USA PATRIOT Act is signed into law and isintended to thwart terrorist activity in the United States. Title III of the Actamends a number of sections under the Bank Secrecy Act and sets outnew compliance requirements for financial institutions.July 23,2002: The Department of the Treasury and the federal financialregulators release proposed customer identification program rules. Theproposed rules implement section 326 of the USA PATRIOT Act and areintended to protect the U.S. financial system from money laundering andterrorist financing. These regulations spell out the requirements forestablishing a customer identification program. One element of a CIP is tocompare names with government lists prior to account opening and reportany matches.

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COMPLIANCEHEADQUARTERS

Section 326 Customer Identification Programs: The Final WordTed Dreyer - Attorney, B ankers Systems, Inc.April 2003Sign Up Now to LearnAbout the Final USAPATRIOT Act Section326 Regulations!Reserve Your SeatToday....More

After months of speculation and anticipation, the U. S. Treasury Department issued final regulations implementingthe Customer Identification Program (CIP) requirements of the USA PATRIOT Act on April 30, 2003. Financialinstitutions across the nation must comply with this new regulation by October 1, 2003. This article will discuss thefinal CIP regulations and address the specific requirements for your institution.OverviewThe USA PATRIOT Act was enacted in October 2001 and contains a number of provisions requiring the financialservices industry to take steps to assist in the war against terrorism. Title III of the Act directly impacts financialinstitutions and amends several sections of the Bank Secrecy Act. Section 326 of Title III requires financialinstitutions to create and implement what is referredto as a customer identification program or CIP. The goal ofsuch a program is to establish a process whereby institutions verify the identity of each customer or member atthe time an account is opened.Following the outline of the proposed regulations, the final CIP regs establish who the law applies to and set outthe key components of a CIP. These components include, identification, verification, government list comparisons,adequate notice and record retention.CoverageThe proposed regulations covered situations where a customer is seeking to open an account. A "customer"included any person or business entity opening the account and any "signatory" on the account. "Account"included any ongoing banking relationship, including lending transactions, deposit accounts or asset accounts.One problem was that there was no definition for the term "signatory" and there was uncertainty as to whetherparties such as guarantors or holders of powers of attorney were covered. ^A second troublesome issue related to the definition of "customer." Under the proposed rule, a customer isanyone seeking to open an account and commenters speculated that it would apply to persons who were deniedaccounts for whatever reason, and require maintaining identification records on persons who ultimately did nothold accounts. A number of questions surfaced regarding how it would apply in the event that a beneficiary ofaccount (e.g. a trust or an IRA) became an account owner on the death of the originally named account holder.For this reason, many letters suggested limiting the definition to those who actually opened accounts.

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