-----Original Message-----
From: John.Ricketti@ny.frb.org [mailto:John.Ricketti@ny.frb.org]
Sent: Friday, March 18, 2005 10:22 AM
To: regs.comments@federalreserve.gov; Comments;
regs.comments@occ.treas.gov; regs.comments@ots.treas.gov
Subject: EGRPRA
Mr. O'Brien has asked me to respond to your letter
dated March 9,2005
seeking feedback on issues involving money laundering
and SAR
compliance.
Having worked on both the Law Enforcement and
Banking side of this
issue I have a few thoughts id like to share.
Increasingly the regulators and law enforcement in
a post 911 world
have been seeking assistance from the banking
community in the
identification of persons involved in money laundering
activities.
We recognize the threat these individuals may pose
to our national
security, and drug enforcement efforts.
We have assumed a larger burden and are responsible
for policing our
customers financial transactions, we welcome the
opportunity to do our
part.
What is problematic though is the increased
responsibility with a lack
of support from the very agencies seeking our help.
On the "know your customer front" we take great
efforts to effectively
identify individuals who bank with us. We request
multiple forms of
identification and utilize a private tracking company
(Chex systems)
which supplies us with negative banking related
reports on a prospective
new customer. We cannot however verify if a Social
Security Number
supplied by a prospective customer belongs to that
individual. It would
be helpful if the Government would verify for us that
a SS number
suppled matches the name submitted (yes - no ).
In suspicious cases we rely on Choice point for
verification
assistance. In light of a recent breach of security
within that company
I am concerned that our continued access to that
information may soon be
terminated.
On the SAR reporting side it seems ridiculous that
a person who has
been identified as a money launderer in another
institution can move
from bank to bank and have to be re-discovered over
and over again. This
individual may operate for a year or two before his
activity attracts
the necessary attention. Can we somehow develop a
"watch list" on these
individuals. Law enforcement agencies should perhaps
have access to the
Chex systems data base as they may want to reach out
to the new bank of
a Suspected Money Launderer.
Paul De Stefano
Director of Security
Atlantic Bank of New York
212 714-7431
