"Brace for the possibility of an immediate increase in requests from the Treasury Department's Financial Crimes Enforcement Network about whether criminal suspects have accounts or have conducted transactions at your firm. Despite industry opposition, FinCEN last week sent a final rule to the Federal Register that will take effect upon publication and expand its 314(a) program to allow local and state law enforcement agencies, and 27 European Union jurisdictions, to make inquiries at your firm. (BD Week, Nov. 30, 2009).
"The program – which helps law enforcement confirm whether people suspected of terrorism or significant money laundering activities have done business at U.S. firms, and which firms those are – is being expanded without the explicit procedures and safeguards the financial industry requested."
Mintz Levin attorney Steve Ganis was quoted in the February 15 issue of BD Week, in "Expect More Inquiries Soon; FinCEN Expanded Information Request Begins."
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