OCC 2004-27
OCC Bulletin

Subject:      Bank Secrecy Act/Anti-Money Laundering
Description:  Designation of Commercial Bank of Syria as a Financial 
              Institution of Primary Money Laundering Concern; Proposed 
              Rule Imposing Special Measures Against Commercial Bank of 
              Syria

Date:         June 16, 2004 


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


The Secretary of the Treasury, through his delegate, the Director of the 
Financial Crimes Enforcement Network (FinCEN), has determined that 
Commercial Bank of Syria (CBS), its branches and subsidiaries (including 
Syrian Lebanese Commercial Bank), is a financial institution of primary 
money laundering concern under section 311 of the USA PATRIOT Act.  On 
May 18, 2004, the Department of the Treasury (Treasury), acting through 
FinCEN, issued the attached proposed regulation to impose special measures 
against CBS.

The special measures to be imposed would prohibit national banks from 
establishing, maintaining, administering, or managing correspondent or 
payable-through accounts in the United States for, or on behalf of, CBS.  
National banks would also be required to apply special due diligence to 
all of their correspondent accounts to ensure that no such account is 
being used indirectly to provide services to CBS.  Special due diligence 
would include notifying correspondent account holders that they may not 
provide CBS with access to the correspondent account maintained at the 
bank, reasonable steps to identify indirect access, and appropriate steps 
to block such access when it is identified.  

Treasury is soliciting comments from all interested parties concerning 
the proposed rule.  Comments must be submitted on or before June 17, 2004.

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




_____________________________
Ann F. Jaedicke
Deputy Comptroller for Compliance 


Attachment—69 FR 28098
	   [http://www.occ.treas.gov/fr/fedregister/69fr28098.pdf]