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International Trade
Newsletter - March 17, 2003
 
In this Issue...
Proposed Regulations Under USA PATRIOT Act – Comment Request
 
March 17, 2003
 

On Monday, February 24, 2003, the U.S. Treasury Department issued an Advance Notice of Proposed Rule Making for Businesses Engaged in Vehicle Sales.  Please note that the term "vehicle" includes automobiles, airplanes, and boats.  This Advance Notice was issued expressly because Treasury is seeking advice and assistance in assessing the benefits and burdens associated with imposing the anti-money laundering program requirement on this industry.  Although Treasury is clearly contemplating regulations that will require businesses engaged in vehicle sales to have formal Anti-Money Laundering Programs, it may also be seriously considering limiting the application of new rules to only a specific part of the industry, or even making the temporary exemption for the industry permanent.

Treasury has requested and invited comment on the following questions.  The responses it receives will very likely determine the scope of any new anti-money laundering and customer identification requirements that will be imposed on the industry.  The specific questions Treasury is asking are:

 

  • What is the potential money laundering risk posed by vehicle sellers?  Do money laundering risks vary by (1) vehicle type (e.g., boat, airplane, automobile); (2) market (wholesale vs. retail); or (3) business line (international sales, sales to governments)?
  • Should vehicle sellers be exempt from coverage under sections 352 and 326 of the PATRIOT Act [the Anti-Money Laundering Program requirement and the Customer Identification requirement, respectively]?         
  • If vehicle sellers, or some subset of the industry, should be subject to the Anti-Money Laundering Program requirement, how should the Program be structured?
  • How should a vehicle seller be defined?  Should there be a minimum threshold value in the definition?  Should it include wholesale and retail sellers?  Should sellers of used vehicles be included?
  • Do vehicle sellers maintain "accounts" for their customers?

 

Treasury requires that comments be submitted in writing on or before April 10, 2003. Because paper mail in the Washington, D.C., area may be subject to delay, commenters are encouraged to e-mail comments.  Comments may be submitted by electronic mail to regcomments@fincen.treas.gov with the caption in the body of the text, "ATTN: ANPRM--Sections 352 and 326--Vehicle Seller Regulations.''  Comments may be mailed to FinCEN, P.O. Box 39, Vienna, VA 22183, ATTN: ANPRM--Sections 352 and 326--Vehicle Seller Regulations. Comments should be sent by one method only.  For more information on this comment request, please see the Federal Register notice online at:  http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/03-4173.htm.