USA PATRIOT ACT COMPLIANCE

The USA Patriot Act has established a matrix of anti-money laundering measures to be undertaken by financial institutions and businesses of many kinds, ranging from federally regulated banks to insurance companies to private investment funds to securities broker/dealers.

The Harmon Firm is uniquely well qualified to provide the following consulting, due diligence and investigative services, aimed at deterrence of money laundering and compliance with The Act:

Anti-Money Laundering Programs

• Development of internal policies, procedures, and controls

• Designation of a compliance officer

• Ongoing employee training program

• Conduct of an independent audit function to test programs

• Private Client Accounts

• Private Accounts of Non-US Persons
  • Identification of nominal and beneficial owners

  • Identification of the source of funds

  • Conduct of enhanced scrutiny of any account connected to a senior foreign political figure, family member or close associate

• Correspondent or Functionally Equivalent Accounts of Non-U.S. Financial Institutions
  • Money laundering risk assessment of a foreign correspondent financial institution

  • Determination of the offshore banking license under which the foreign correspondent financial institution operates, and whether the license was issued by a foreign country that has been designated as non-cooperative with international anti-money laundering principles or procedures

  • Research of information available from U.S. governmental agencies and multinational organizations with respect to supervision and regulation applicable to the foreign correspondent financial institution

  • Review of guidance issued by Treasury or a Federal functional regulator regarding money laundering risks associated with particular foreign financial institutions and correspondent accounts for foreign financial institutions

  • Review of guidance issued by Treasury or a Federal functional regulator regarding money laundering risks associated with particular foreign financial institutions and correspondent accounts for foreign financial institutions generally

  • Review of public information to ascertain whether the foreign financial institution has been the subject of criminal action of any nature, or regulatory action relating to money laundering

  • Identification and verification of each owner of a foreign correspondent financial institution and the nature and extent of each owner's ownership interest

  • Identification and verification of foreign financial institutions having correspondent relationships with a questioned foreign correspondent financial institution

  • Conduct of enhanced scrutiny and evaluation of the anti-money laundering program of a foreign correspondent financial institution, including monitoring of transactions through the correspondent account, and ascertaining and verifying the identity of any persons that will have authority to direct transactions through the correspondent account

• Shell Banks - Policies and Detection Methods

• Concentration Accounts - Policies and Detection Methods

• Payable-Through Accounts - Policies and Detection Methods

  Suspicious Activity Report Procedures

  Procedures for Sharing Information Among Financial Institutions, Law Enforcement and Intelligence Agencies