OCC 2006-19
OCC Bulletin  

    Subject:  Bank Secrecy Act/Anti-Money Laundering

Description:  Final Rule: Imposition of Special Measures Against
              the Commercial Bank of Syria including its
              subsidiary, the Syrian Lebanese Commercial Bank as
              a Financial Institution of  Primary Money Laundering
              Concern

       Date:  April 18, 2006


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

The Financial Crimes Enforcement Network (FinCEN) issued a final
rule on March 9, 2006, that imposes special measures against
Commercial Bank of Syria (CBS), including its subsidiary, Syrian
Lebanese Commercial Bank.  The rule follows the Secretary of the
Treasury's May 11, 2004, designation, under section 311 of the
USA PATRIOT Act, of CBS, along with its subsidiary, Syrian
Lebanese Commercial Bank, as a financial institution of primary
money laundering concern (see OCC Bulletin 2004-27).  A copy of
the Federal Register notice, dated March 15, 2006, is attached.

Effective April 14, 2006, national banks must terminate any
correspondent account that is established, maintained, or payable-
through in the United States for, or on behalf of, CBS.  Also,
national banks are required to apply due diligence to
correspondent accounts that is reasonably designed to guard
against indirect use by CBS.  At a minimum, that due diligence
must include notifying correspondent account holders that the
correspondent account may not be used to provide CBS with access
to the correspondent account; taking reasonable steps to identify
any indirect access and appropriate steps to prevent such
indirect access; and documenting compliance with the notice
requirement to correspondent account holders.

For further information, please contact your examiner-in-charge,
your OCC supervisory office, or the Compliance Department at
(202) 874-4428.




_____________________________
Ann F. Jaedicke
Deputy Comptroller for Compliance Policy


Attachment-71 FR 13260
       [http://www.occ.treas.gov/fr/fedregister/71fr13260.pdf]