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SCAN THIS NEWS

12/6/98

KYC to have major consequences -

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More on KYC available at:

http://www.networkusa.org/fingerprint.shtml  

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The "Know Your Customer" program is international in origin. It is being promoted by the international organization known as the "Financial Action Task Force" (FATF) in compliance with international treaties. While FATF-prepared reports (regarding the KYC program) state that compliance by member organizations (meaning both countries and banking institutions) is "voluntary," non-compliance will result in ostracization from the global banking community. As this concept filters down, likewise bank customers who do not "volunteer" into the KYC program will be denied access to all banking-related services.

Under KYC requirements, all financial transactions will be monitored, and every interaction with a bank will require identification. Also, non-bank financial exchanges above a given threshold will likewise require identification.

The pretext for the KYC requirements is in detecting illegal money transfers and tax evasion. To accomplish the KYC objective, international cooperation is essential.

In reading over the FATF's KYC documents, certain concepts are repetitively emphasized. Typically, cash is portrayed as "evil," (only people with something to hide conduct business using cash). Anyone who will not identify themselves to a bank is likely engaging in some illegal activity, or they have something to hide. Monitoring is imperative, and "customer profiling" is an integral part of the overall KYC plan.

Ultimately, cash-on-hand amounts will be limited by law which will necessitate electronic methods of payment for items over a given amount - probably $100, (while this is not absolutely stated in FATF documents, it is a fair conjecture based on inference). In such case, anyone holding amounts of cash larger than the legally allowed limit will be charged with a crime. One thing that is openly stated is that anyone who will not identify themselves will not be allowed to conduct business with a bank.

Full implementation of KYC policies will have a tremendous consequences for the way we conduct business in the future. Some of these consequences are:

IDENTIFICATION REQUIREMENTS:

o Identification will be required for all business transactions which use conventional methods of payment, i.e.: checks, credit cards, debit cards, money orders, wire transfers, and electronic transfers.

o Cash deposits and withdrawals above certain thresholds will require identification.

o Identification will also be required for: renting safety deposit boxes, purchasing insurance, and stock transfers.

o Customers who will not identify themselves will not be allowed to use bank services.

o New technologies using methods of "electronic identification" are encouraged.

LIMITATIONS TO BE PLACED ON CASH, GOLD:

o Cash transactions will be monitored through deposits and withdrawals.

o Electronic transactions will be logged into an information database and compared against pre-established profiles.

o Limits will be placed on the amount of cash that can be withdrawn at any given time and consecutive withdrawals may be treated cumulatively as one transaction for reporting purposes. Transactions exceeding the allowed limit will result in a "suspicious transactions" report being filed.

o Further limits to be placed on the amounts of money that can be transported across international borders - including both cash and electronic funds transfers.

o Ultimately, cash will likely be outlawed above a certain amount, and conducting private business using cash in amounts larger than the legal limit will constitute criminal activity.

o Gold acquisitions will be monitored and regulated.

MONITORING OF TRANSACTIONS:

o Bank customers will be required to reveal all sources of revenue (income). Accounts will be monitored to evaluate actual deposits compared against projections.

o Banks will establish profiles, classifications, and categorizations based on information supplied by the customer and other gathered information. All customers will be compared against the subjective classifications. Anomalies in deposits or withdrawals will be reported as "suspicious activity."

o Banks are prohibited from informing customers when suspicious transaction reports have been filed on them.

o Modern "new technologies" to monitor and regulate cross-border transfers of cash will be instituted.

NEW "ELECTRONIC PAYMENTS" TECHNOLOGIES PROMOTED:

o Electronic funds transfers are the preferable under the Know Your Customer program because they can be monitored, recorded, and traced. Therefore, debit cards and electronic purses are encouraged for conducting business under KYC.

INTERNATIONAL IMPLEMENTATION:

The "Know Your Customer" program is an international requirement being promoted by the Financial Action Task Force (FATF), whose members include: Australia, Austria, Belgium, Canada, Denmark, European Commission, Finland, France, Germany, Greece, Ireland, Italy, Japan, Luxembourg, the Netherlands, Norway, Portugal, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States. Other international supporting organizations included: Interpol, the International Organization of Securities Commissions (IOSCO), the World Customs Organization (WCO) and the United Nations International Drug Control Programme (UNDCP).

CONCLUSION:

o Under the "Know Your Customer" requirements, people who refuse to "identify" themselves when requested will be precluded from conducting business using contemporary methods of commerce. And those who agree to the identification requirements will have their financial transactions monitored.

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SOURCES:

[1]

FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING (FATF) 1997-1998 REPORT on MONEY LAUNDERING TYPOLOGIES 12 February 1998

FATF-IX REPORT on MONEY LAUNDERING TYPOLOGIES http://www.treas.gov/fincen/typo97en.html  

also at:

http://www.networkusa.org/fingerprint/page1b/fp-fatf-moneylaundering.htm  

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[2]

FINANCIAL ACTION TASK FORCE (FATF)

EVALUATION OF MEASURES TAKEN BY FATF MEMBERS DEALING WITH CUSTOMER

IDENTIFICATION

http://www.oecd.org/fatf/evaluati2.htm  

also at:

http://www.networkusa.org/fingerprint/page1b/fp-fatf-identification.htm  

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[3]

BOARD OF GOVERNORS OF FEDERAL RESERVE SYSTEM

WASHINGTON, D. C. 20551

DIVISION OF BANKING

SUPERVISION AND REGULATION

SR 97-19 (SUP)

June 30, 1997

http://www.kc.frb.org/bs&s/guidance/sr97-19.txt  

also at:

http://www.networkusa.org/fingerprint/page1b/fp-frb-kyc-report.htm  

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