Question or Topic 

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The Question:  What must professionals include in the policies and procedures to comply with the USA Patriot Act (H.R. 3162)

Objectives - this Act changes the way the following professions do businesss:

1. Legal Counsel

2. Broker / Dealers, Financial Advisory Professionals

3. Any Financial Institution

4. Other Professionals serving the above

Related Articles (to be added)

The Answer

Here are some links to the Bill and the President's signing

USA Patriot Act Signed by President Bush

USA Patriot Act (H.R. 3162)

Section 352(a) of the USA Patriot Act amends the federal money laundering statute, 31 U.S.C. Sect. 5318(h), and requires that every "financial institution" establish an anti-money laundering program.

The definition of "financial institution" includes "persons involved in real estate closings and settlements." [31 U.S.C. Sect. 5312 (a)(2)(U).]

Under Sect. 352, any financial institution must have an anti-money laundering program - which, at a minimum, includes:

1. The development and implementation of written internal policies, procedures and controls;

2. The designation of a compliance officer;

3. An ongoing employee training program; and

4. An independent audit function to test the program.

The Secretary of the Treasury will author Regulations which guide the professional adviser and the financial institutions.  The Treasury Department will decide whether to apply it to lawyers.

Solutions

Solutions are dependent upon facts & circumstances, law and the objectives.  These elements vary from one time to another, from one circumstance to another and from person or entity to another.

Kit to Prepare for Your Adviser

- To be completed later

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