Client Alert

FinCEN Final Patriot Act Regulations on Special Due Diligence Program

September 12, 2007

The Investment Management Practice Group

The Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury has issued a final rule (the Final Rule) implementing a key provision of Section 312 of the USA PATRIOT Act. The Final Rule clarifies the risk-based procedures that U.S. financial institutions should use in tailoring their enhanced due diligence to assess the risks of certain foreign banking relationships.

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Investment Management

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