OCC 2002-1
OCC Bulletin
Subject: Bank Secrecy Act/Anti-Money Laundering
Description: Interim Guidance on Compliance with the 
             USA PATRIOT Act
Date: January 4, 2002

TO:  Chief Executive Officers and Compliance Officers of 
     All National Banks and Federal Branches, Department 
     and Division Heads, and All Examining Personnel

The attached notice provides interim guidance to 
financial institutions on how to comply with two anti-
money laundering provisions of the Uniting and 
Strengthening America by Providing Appropriate Tools 
Required to Intercept and Obstruct Terrorism (USA PATRIOT) 
Act of 2001.

Effective December 25, 2001, financial institutions are 
prohibited from providing correspondent accounts directly
to foreign shell banks and are required to take steps to 
ensure that correspondent accounts are not being used 
indirectly to provide banking services to such shell banks.
In addition, financial institutions are required to keep 
records of the owners of foreign banks to which they 
provide correspondent accounts and of the foreign banks' 
agent designated to accept service of legal process.  
Attached is a model certification that U.S. banking 
institutions may use to assist them in meeting these 
obligations.

It is the expectation of the Department of the Treasury 
that financial institutions will accord priority to 
meeting their compliance obligations in connection with 
foreign banks for which they maintain correspondent 
deposit accounts.  However, the requirements also apply 
to nondeposit relationships with foreign banks.  The 
interim guidance will remain in effect until superseded 
by regulation or subsequent guidance.  A link to the 
interim guidance can be found in the U.S. Department of 
Treasury's Web site, www.treas.gov/press/.

Questions may be directed to your OCC supervisory office 
or the Compliance Division at (202) 874-4428.



___________________________________
David G. Hammaker
Deputy Comptroller
Compliance

Attachment - 66 FR 59342