The importance of anti-money laundering measures has been tragically highlighted by the recent terrorist attacks in the United States. International groups such as the Organization for Economic Cooperation and Development have called repeatedly for regulations to be tightened to prevent money laundering and profiteering by criminal groups. Governmental and bank supervisory agencies in the United States and elsewhere have also cited the link between money laundering and terrorist activity. The Securities and Exchange Commission (SEC), for example, has been reviewing records indicating possible terrorist involvement in US securities markets.

On September 17 2001 the Federal Bureau of Investigation (FBI) provided the Federal Reserve Board and the other financial institution supervisory agencies with a public list of the names of alleged suspects under investigation by the FBI in connection with the World Trade Centre and Pentagon attacks. The FBI has asked all domestic and foreign banking organizations operating in the United States to check their records for any relationships or transactions with the named individuals.

A banking organization identifying a relationship, such as a bank account, or a transaction, such as a wire transfer, with any of the named individuals should follow applicable rules for filing suspicious activity reports.

As indicated in Banks Must Step up Measures against Money Laundering, written just before the terrorist attacks, anti-money laundering policies and procedures should continue to be a primary focus of bank compliance programmes.

For further information on this topic please contact Connie Friesen at Sidley Austin Brown & Wood LLP by telephone (+1 212 906 2000) or by fax (+1 212 906 2021) or by e-mail ([email protected]).
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