Money laundering deadline

Money Laundering Deadline Nears

April 24, 2002 compliance date approaches.

By John M. Baker, Esq.

As I write this, we are one month from April 24, 2002, the date on which financial institutions are required to establish anti-money laundering programs, including, at a minimum–

(A) the development of internal policies, procedures, and controls;

(B) the designation of a compliance officer;

(C) an ongoing employee training program; and

(D) an independent audit function to test programs.

The requirement is contained in section 352 of the inelegantly-named Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT) Act of 2001, Public Law 107-56 (adding 31 U.S.C. § 5318(h)), and takes effect by operation of law, although the Secretary of the Treasury is supposed to prescribe interpretive regulations.

“Financial institution” is defined in 31 U.S.C. § 5312 and includes, among others, banks, broker-dealers, investment companies, and, apparently, real estate lawyers. The Securities and Exchange Commission reportedly will allow management to adopt the program, without the necessity of a formal board vote before April 24.

NASD Regulation has a page of links to resources at The statute itself, and other current public laws, is available in text and PDF format at

For an article on the possible application to lawyers, see



Copyright 2000, John M. Baker, Esq., Stradley, Ronon, Stevens & Young, LLP, 1220 19th Street, N.W., Suite 700, Washington, DC 20036 – (202) 822-9611- Fax (202) 822-0140 This article was originally posted to the FundLaw List, To subscribe to FundLaw, send a blank e-mail to