USA PATRIOT Act compliance - or something very much like it - will eventually be mandatory across the entire financial services industry. Many enterprises currently outside of its regulatory reach are adopting customer identification programs and transaction mining systems anyway, as their use reflects sound business judgement on a number of fronts. Compliance, though, is more than the simple one-time acquisition of software or imposition of business processes. Adequate ongoing funding must be provided for:Knowing your Customer
Acquiring and preserving adequate identification, behavioral and transaction data to facilitate the profiling of "normal" customer behavior and determine the beneficial owner of business clients. Covered firms are required to be not only "reasonably certain" regarding the identity of their customers but also must determine whether the source and destination of their customers' funding is unlawful. Detailed, accurate and timely personal and/or corporate information will be needed to perform link and "householding" analyses of accounts.
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