Since the promise of further USA PATRIOT Act promulgation by the U.S. Treasury Department fell away in June, life insurance and annuity companies have been holding their breath, waiting for an imminent vote by the 109th Congress that could add even more regulatory compliance requirements for carriers.And while the final version of Section 352 of the USA PATRIOT Act may be looming, what it will mean for the life insurance industry is still in question.

The PATRIOT Act, passed within a month of Sept. 11, 2001, is considered an amendment or reiteration of the Bank Secrecy Act of 1970. Section 352 of the PATRIOT Act required all financial institutions, as defined by the Bank Secrecy Act, to establish an anti-money laundering (AML) program within six months of the passage of the Act.

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