USA PATRIOT ACT: Better Interagency Coordination and Implementing Guidance for Section 311 Could Improve U.S. Anti-Money Laundering Efforts [open pdf - 755KB]
"Since September 11, 2001, the United States has established tools to address the threat to the U.S. financial system of money laundering and terrorist financing. One such tool is Section 311 of the USA PATRIOT Act of 2001, which authorizes the Secretary of the Treasury (Treasury) to prohibit U.S. financial institutions from maintaining certain accounts for foreign banks if they involve foreign jurisdictions or institutions found to be of primary money laundering concern. To make this finding, Treasury examines several factors and generally issues a proposed rule announcing its intent to apply Section 311 restrictions. GAO was asked to examine the process used to implement Section 311 restrictions, the process Treasury follows to finalize or withdraw a proposed rule, and how Treasury assesses the impact of Section 311. GAO reviewed financial and investigative U.S. government documents and met with government officials and representatives of affected banks. GAO recommends that Treasury establish guidance to clarify responsibility to implement and finalize Section 311 actions. Treasury said it will act in response to this recommendation, although the process has been improved. Justice and State did not comment."
Government Accountability Office (GAO): http://www.gao.gov/