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The USA Patriot Act and Private Equity Funds

By Steven R. Block
August 03, 2003

The Patriot Act (official title: The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Public Law 107-56) was signed into law by President Bush on October 26, 2001. Title III of the Act impacts the anti-money laundering provisions of the Bank Secrecy Act (BSA). The amendments were made to promote the prevention, detection, and prosecution of international money laundering and the financing of terrorism.

The Patriot Act amended section 5318(h) of the BSA and requires “financial institutions” to carry out anti-money laundering programs, including at a minimum:

1. the development of internal policies, procedures, and controls;

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