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Industry Awaits Regulations under USA Patriot Act

By John F. State
September 11, 2003

The USA Patriot Act was signed into law by President Bush on October 26, 2001 (the 'Enactment Date'). Its stated purpose is to enable law enforcement officials to track down and punish those responsible for the 9/11 terrorist attacks and to protect against any similar attacks.

The act is officially titled: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA Patriot Act) Act of 2001.

This is the first in a series of articles intended to address the impact on non-bank affiliated leasing companies of those provisions of the USA Patriot Act that relate to anti-money laundering and customer identification programs. In general, these provisions will impose compliance requirements on many companies involved in the leasing industry which ' to date ' have not been regulated on these issues. The next article in this series will be published following the issuance by the Treasury Department of regulations relevant to the 'loan and finance company' category of 'financial institution'; these regulations are expected in the next few months.

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