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USA PATRIOT Act

Are you a "financial institution"? If so, are you prepared for the new regulations under the USA PATRIOT Act? (Even if you are not, are you OFAC compliant?) If you think that you might be on this list, please read below. It may save your company and your freedom.

A "financial institution" is defined in the BSA (Bank Secrecy Act) to include:

(A) An insured bank (as defined in Section 3(h) of the Federal Deposit Insurance Act);
(B) A commercial bank or trust company;
(C) A private banker;
(D) An agency or branch of a foreign bank in the United States;
(E) An insured institution (as defined in section 401(a) of the National Housing Act);
(F) A thrift institution;
(G) A broker or dealer registered with the Securities and Exchange Commission;
(H) A broker or dealer in securities or commodities;
(I) An investment banker or investment company;
(J) A currency exchange;
(K) An issuer, redeemer, or cashier of traveler's checks, checks, money orders, etc.;
(L) An operator of a credit card system;
(M) An insurance company;
(N) A dealer in precious metals, stones, or jewels;
(O) A pawnbroker;
(P) A loan or finance company;
(Q) A travel agency;
(R) A licensed sender of money;
(S) A telegraph company;
(T) A business engaged in vehicle sales, including automobile, airplane & boat sales;
(U) Persons involved in real estate closings and settlements;
(V) The United States Postal Service;
(X) A casino, or gaming establishment with annual gaming revenue of $1,000,000;
(Y) Any business or agency which engages in any activity which the Secretary of the Treasury determines by regulation, to be an activity which is similar to, related to, or a substitute for any activity described in this paragraph; or
(Z) Any other business designated by the Secretary whose cash transactions have a high degree of usefulness in criminal, tax or regulatory matters.
If you are on the above list, and cannot confidently state that you have adequate controls for customer identity validation, then MIS can make you USA PATRIOT Act compliant. Please contact MIS to discuss how this can easily be implemented.

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