Re: Treasury Department Interim Guidance on Compliance
with Sections 313 and 319(b) of the USA PATRIOT Act


                    Attached is a memorandum from Sullivan & Cromwell concerning the above subject. A summary is also included at the end of the text of this e-mail message.

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SUMMARY

                    Two anti-money laundering provisions of the USA PATRIOT Act, sections 313 and 319(b), become effective on December 25, 2001.  Late Tuesday, the Treasury Department announced interim guidance (the ''Interim Guidance'') for banking institutions on compliance with those sections.  The

Interim Guidance is based on a certification that would be submitted by foreign respondent banks to their U.S. correspondent banks.






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