URGENT/ACTION REQUESTED
[14733]
May 20, 2002
TO: MONEY LAUNDERING RULES WORKING GROUP No. 25-02
RE: DRAFT LETTER TO TREASURY ON MUTUAL FUND AML PROGRAM RULE
As you know, the Department of the Treasury’s Financial Crimes Enforcement Network
(FinCEN) recently issued an interim final rule that would prescribe minimum standards for
anti-money laundering compliance programs established by mutual funds.1 Attached for your
review is a draft of the Institute’s comment letter on this interim final rule.
The comment letter discusses five issues: (1) the treatment of omnibus and similar
accounts; (2) AML compliance officers’ titles; (3) the delegation of AML compliance functions;
(4) reporting on Form 8300; and (5) compliance enforcement. We are seeking input from the
working group on all aspects of the draft letter. However, in particular, we would be interested
in comments on the section on omnibus accounts and the distinction drawn between omnibus
accounts and “broker-controlled” accounts.
The letter must be submitted to Treasury by May 29th. If you have any comments on
the attached draft, please contact me at (202) 371-5430 (email: rcg@ici.org) or Frances Stadler at
(202) 326-5822 (email: frances@ici.org) by the close of business on Friday, May 24th.
Robert C. Grohowski
Associate Counsel
Attachment (in .pdf format)
1 See Memorandum to Money Laundering Rules Working Group No. 22-02, dated April 25, 2002.