Publications

Mutual Fund Compliance and the Anti-Money Laundering Regulatory Regime (Part II)

September 5, 2007
The Review of Securities & Commodities Regulation

PATRIOT Act Regulations Impose on Mutual Funds Obligations to File Suspicious Activity Reports, to Share Account Information with Law Enforcement, and to Engage in Enhanced Due Diligence for Certain Correspondent Accounts.

This article is the second half of a two-part series describing the anti-money laundering ("AML") components of mutual fund compliance. The first part of this article addressed the AML provisions adopted prior to the USA PATRIOT Act, which was passed in October 2001. Before the PATRIOT Act, mutual funds already were subject to the federal criminal AML statutes, cash transaction reporting requirements, and the sanctions programs administered by the Office of Foreign Assets Control.