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

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1/14/04 USA PATRIOT Act Monitor News Release: Bank Contact Information Procedure Updated

Contact Information of National Banks To Be Processed Electronically

The electronic system under which law enforcement agencies request information about suspected terrorists and money launderers under section 314(a) of the USA PATRIOT Act is being updated. Although the system is basically electronic, contact information regarding national banks and financial institutions has been processed manually by the Office of the Comptroller of the Currency after a bank or branch sends an email to the OCC at nationalbankinfo@occ.treas.gov. During the first quarter of 2004, according to OCC Alert 2004-1 (http://www.occ.treas.gov/altlst04.htm), the process will be automated by electronic processing of information filed in the Call Report. The Call Report instructions require institutions to include 314(a) contact information for a maximum of two contacts when filing a Call Report. The information will be shared with FinCEN to create a new distribution list for sending 314(a) requests to financial institutions. In submitting contact information to the OCC (and thus to FinCEN), Alert 2004-1 notes that a common mistake is to forget the @ in an email address, sometimes replacing it with a period, producing something like edeltahedge.aol.com (which would probably work as a website address, but will not function in the email system). Because of the two-contact limitation, the Alert notes that institutions desiring "more than two contacts for receiving the 314(a) requests will have to establish either a shared e-mail address that will provide access for these additional contacts, or an internal distribution process for disseminating the 314(a) requests to its additional contacts" Once the new system is operational, national banks will no longer have to provide changes by sending an email to nationalbankinfo@occ.treas.gov.

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