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FDIC Federal Register Citations |
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From: Kurt Kormann Sent: Friday, July 26, 2002 11:50 AM To: Comments Cc: Reese Cropper Jr.; Ray Thompson; Bill Mitchell Subject: Customer Identification Programs for Banks I have a concern about the implementation of Section 326 of the USA Patriot Act. I believe that financial institutions, in general, identify and verify customers at the account opening stage and maintain records of this. The concern I have is the proposed requirement to consult the control lists of known or suspected terrorists. Many financial institutions use a "screening service" at the account opening process for "know your customer" and OFAC screening purposes. The problem that I foresee with the requirement to consult the "control lists" is that these lists are not distributed to the "screening service" companies. Therefore, this must be done manually now. There is no way that this can be done as effectively "manually" as it would be done by the screening service companies. I know when these lists first came out, they were supposed to be very secretive. At this point, however, the screening service companies have knowledge of these lists and are scrambling around in preparation to offer this service, with the mindset that these lists will soon be released to them. I am proposing that the restrictions be lifted that prohibits the customer screening services from receiving these lists. This will make the purpose of the USA Patriot Act, in preventing terrorism, to be much more effective. |
| Last Updated 07/26/2002 | regs@fdic.gov |