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The USA PATRIOT Act Renewed: Reassessing Money Laundering Risk in Finance Transactions

By Stephen J. McHale and David G. Mayer
October 30, 2006

Part One of a Two-Part Series

The federal government is stepping up its aggressive enforcement of anti-money laundering/combating the financing of terrorism ('AML/CFT'). Enforcement actions have already spread beyond 'traditional' financial institutions, such as banks. Regulations that are expected to be promulgated soon will likely embolden these enforcement actions against leasing companies, equipment vendors, finance companies, and other 'financial institutions.' These parties should reassess their compliance risk under the AML/CFT rules. The consequences of these risks are important. For example, the loss of reputation from being brushed with the taint of money laundering can sink a business.

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