Notices to Members

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Notice I-06-14 REVISED

August 8, 2006

USA Patriot Act Special Due Diligence Program For Certain Foreign Accounts (Attention: Member FCMs and IBs)

On January 4, 2006, the Financial Crimes Enforcement Network (FinCEN) issued a Final Rule that requires FCMs and IBs to establish due diligence programs that are reasonably designed to detect and report money laundering through correspondent accounts and private banking accounts established or maintained for non-U.S. persons. The final rule was effective July 5, 2006. The full text of the rule may be found at [hyperlink updated 10/20/21].

FCM and IB Members should incorporate these due diligence programs into their existing AML program. In developing these programs, FCMs and IBs should review the final rule, as well as two Guidance releases issued by FinCEN. These guidance releases may be viewed at [hyperlink updated 10/20/21] and [hyperlink updated 10/20/21].

If you have any questions on the requirements, please contact Carol Wooding, Assistant General Counsel, at (312) 781-1409 or, Sharon Pendleton, Director, Compliance, at (312) 658-6540 or, or Denise Bent, Manager, Compliance, at (312) 781-1483 or

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