Chapter 2 - US Legislative and Regulatory Initiatives

Question 1

USA Patriot Act (What it stands for)

Answer 1

Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism

Question 2

USA Patriot Act - Title III (Content and applicability)

Answer 2

Contains most AML provisions in this law
Applicable to US and non US institutions operating in US (international access points to the US financial system must be controlled)

Question 3

Patriot Act - Section 311

Answer 3

Special Measures for Primary ML Concerns, foreign countries or banks can be designated Primary ML Concern, US government can force US banks to cease business or provide information about those foreign banks

Question 4

Patriot Act - Section 312

Answer 4

Requires DD or EDD on correspondent relationships and PB accounts

Question 5

Patriot Act - Section 313

Answer 5

Prohibition on correspondent banking accounts for foreign shell banks

Question 6

Patriot Act - Section 314

Answer 6

Cooperation and information sharing between banks and authorities

Question 7

Patriot Act - Section 319a

Answer 7

US government can seize funds from a CB account in US from a foreign institution

Question 8

Patriot Act - Section 319b

Answer 8

Banks must produce information relating to accounts managed in US within 120h

Question 9

Money Laundering Act 1986 - “SUA”

Answer 9

Specified Unlawful Activity = activity from which derived funds are classified as illegal (virtually all crimes that produce an economic advantage)

Question 10

OFAC - Role

Answer 10

enforces economic and trade sanctions based on US foreign policy and national security goals