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As the first line of defense against the cowards who reek their fanaticism against free nations, Congress passed and President George W. Bush signed into law The USA Patriot Act of 2001.
One aspect of The USA Patriot Act requires financial institutions to match their existing and potential customers against the Office of Foreign Control (OFAC) list of suspected terrorists entities and individuals and other "watch lists". Customer identification programs are now required of virtually all US. financial institutions including banks, mutual funds, credit unions and securities dealers. This also includes anyone involved in cash transactions over $10,000.00. The key to compliance with this law is to “know your customer.”
Section 326 of the USA Patriot Act, in summary, calls for the following:
- Verifying the identity of any person seeking to open an account, to the extent reasonable and practicable;
- Maintaining records of the information used to verify the person’s identity, including name, address, and other identifying information; and
- Determining whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the financial institution by any government agency.
What does this mean?
- All Financial Institutions must have a Policy (Customer Identification Program) detailing its Identity Verification Program.
- All new accounts need to be screened against the OFAC, and other published lists of suspected terrorists and terrorist organizations.
- Any documents used to identify the new account holder, such as, drivers license, passport, social security card, etc., need to be verified against a third party database to determine that the identity is valid to extent reasonable and practicable.
A database of all accounts needs to be maintained that includes the account name, date of account opening, identifying information presented, and the items used to verify the identity. This information needs to be time and date stamped and maintained for 5 years following the closure of the account.
To help you meet these new requirements, we now offer GlobalScanTM as our USA PATRIOT ACT conforming search, which quickly searches all the following databases:
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OFAC Specially Designated Nationals (SDN) & Blocked Persons
OAC Sanctioned Countries, including Major Cities & Ports
Noncooperative Countries and Territories
Department of State Trade Control (DTC) Debarred Parties
US. Bureau of Industry & Security (formerly BXA)
FBI Most Wanted Terrorists & Seeking Information
FBI Top Ten Most Wanted
INTERPOL Most Wanted List
Bank of England Sanctions List
OSFI - Canadian Sanctions List
United Nations Consolidated Sanctions List
Politically Exposed Persons List
European Union Terrorism List
World Bank Ineligible Firms
