Less than 2 months after 9/11, President Bush signed the USA PATRIOT Act.
The USA PATRIOT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“U.S.A. P.A.T.R.I.O.T.”) Act, announced a wide range of new tools to strengthen the U.S. economic system from, in addition to many other things, money laundering, terrorist financing, identity theft, and fraud.
Among the tools of the USA PATRIOT Act was Section 326, which virtually overhauled the account-opening process at financial institutions.
Section 326 required that the Treasury Department establish minimum standards with which financial institutions must strictly comply in order to open new accounts.
This note will outline a brief history and a few aspects of Section 326 with which we are all now faced.