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10. Upon request, the Federal Reserve banks provide Treasury with
information regarding currency surpluses by banks in a given
Treasury can then analyze that information and compare
it to Currency Transaction Report levels of the banks.
way, potential violators can be identified.
Such an analysis as
you know, identified institutions in the New England area, such as
Bank of Boston. Customs did such an analysis last summer of banks in Louisiana, which was forwarded to the supervisory agencies. А
similar analysis is being done now of banks in Texas.
11. As set forth above, we are now satisfied that banking
regulators have detailed Bank Secrecy examination procedures and
we have been assured that they will apply those procedures.
12. Bank examiners have not been provided systematically with
records of the BSA forms that have filed in order to verify that
examined institutions have actually filed the forms. Bank examiners have brought to our attention that this information would be a useful. We are consider ing ways to address this problem, e.g., giving the examiners limited on-line access to the
Bank Secrecy Act data base for this purpose.
13. The regulation that authorizes Treasury to select banks for
special reporting of transactions including wire transfers, with
foreign financial agencies became effective July 8, 1985.
Internal Revenue Service Criminal Investigation Division is
currently developing a pilot program for the use of this
We are hopeful that this new regulation
will be very effective in detecting illegal actiivity, focusing
Treasury's financial enforcement efforts and identifying needs for international law enforcement cooperation initiatives.
14. We believe that the term "monetary instruments" under the BSA
does include postal money orders, if they are issued in blank or
to a fictitious payee.
However, Treasury has not designated the
Postal Service as a financial institution subject to the reporting and recordkeeping provisions of the Act. As testimony before your Committee demonstrated, postal money orders may be the next frontier for money launderers as Bank Secrecy Act compliance by
financial institutions improves.
As a direct result of the
hearing, we intend immediately to discuss the problem with the
The Subcommittee appreciates your appearance at our hearings last Thursday. Your testimony is of great assistance in our review of the Bank Secrecy Act and other pertinent issues.
There are several questions which the Subcommittee would like to have you answer and which will be submitted for the record. They are as follows:
Both Mr. Serino, of the Office of the Comptroller
abusing the privacy rights of the legitimate
concerning names and businesses which may
that appropriate entities are on such lists? Assuming there is an unqualified name or business on such a list, what types of enforcement action would your agency pursue ? At present, would civil or criminal liability be possible against either the financial institution or its exempted customer for inappropriately appearing on such a list?
Should the term "monetary instruments" in the Bank Secrecy Act and its regulations be amended to include "postal money orders" in order to include them under the requirements of the Act and its regulations?
Has any thought been given to the use of the civil
Again, the Subcommittee is appreciative of your efforts in this area. Please submit your responses to the Subcommittee no later that May 7, 1986.
In your April 25, 1986 letter to James R. Dudine, Chief of the Special
L. William Seidman