Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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5/18/2007 Final AML Rules Coming for Investment Advisers, Commodity Trading Advisors, and Commodity Pool Operators

The Annual Report of the Financial Crimes Enforcement Network states that the agency expects in 2007 to finalize AML program rules for investment advisers, commodity trading advisors, and commodity pool operators. The Report also indicates that rules may be proposed for loan and finance companies. As to the possibility of lowering the recording threshold on funds transmittals from $3,000 to $1,000, the Report indicates that FinCEN plans to “establish an approach for responding to comments on the question of whether to lower the dollar threshold for the requirement to collect, retain, and transmit information transmittals of funds.” Presumably this means the idea is still under consideration (see “Lowering $3,000 Transfer Threshold Proposed” in the July 2006 Monitor). As for implementing a reporting requirement on cross-border funds transfers, FinCEN continues to estimate that developing the technology for such a reporting system will take about three years. This was the estimate in FinCEN’s October 2006 feasibility study (see “Cross-Border Funds Transfer Reporting System on the Way (Regulations Next)” in the April 2007 Monitor), and the implementation of such a system continues to seem rather distant. Other issues raised by FinCEN’s Annual Report will be discussed in forthcoming issues of the Monitor.

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