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The government has a lot of homework to do. In October, Congress passed the Patriot Act, a sweeping anti-terrorism law that enlists financial institutions in the war against funding terrorists. But to meet these new obligations, corporations need guidance from the Treasury Department, which will oversee many of the new regulations. Many in the private sector worry that Treasury won’t be able to meet the act’s deadlines. It’s par for the course, says Robert Serino, former deputy chief counsel of the Office of the Comptroller of the Currency. “Here’s the [same old] problem with Treasury: They have all this responsibility and no bodies to do it.” A sampling of key 2002 deadlines: � February: The new law allows industry, regulators and police to swap information on terrorist groups around the world. The Treasury has to explain what kind of information (for example, evidence of a link between drug traffickers and terrorists) and how it can be shared. � April: Financial institutions must have a four-part anti-money-laundering program that includes “internal policies, procedures, and controls.” This month the Treasury is supposed to explain how that applies to different companies. � April: Banks have to implement new procedures for establishing and monitoring foreign bank accounts, both private and “correspondent” (a domestic account held by a foreign bank to conduct money transfers on behalf of its customers). The Treasury is to say what “reasonable steps” must be taken. � April: Reports due from the Treasury on applying “know your customer” rules to foreigners, and on ways to improve reporting by the industry of suspicious account activity. Also expected: a recommendation on whether the Internal Revenue Service should continue to process suspicious activity reports; if SAR processing is pulled from the IRS, Congress wants to know which agency should take over and how much it’s going to cost. � July: The Treasury is to launch a “highly secure” network that’s supposed to allow instant communication between industry and government on potential terrorist activity. � July: Final regulations are due detailing how and when broker-dealers must report suspicious activity.

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