Date: March 28, 2016

It may surprise money laundering compliance officers and others who know the money laundering and financial crime provisions of the USA Patriot Act to learn that the law contains a “Trade Sanctions” provision. Section 221 of the landmark act sought to tighten trade sanctions and export controls aimed at terrorists and nations and organizations that pose threats to the U.S.

Section 221 is found in Title II which is named “Enhanced Surveillance Procedures.” Title III, on the other hand, is named the “International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001” and is where the anti-money laundering and terrorist financing provisions of the omnibus law are found.

The AML and terrorist financing provisions in Title III are the “300 series” of the act, such as Sections 326, 319, 318, 311. Nearly all of these sections were codified in the Bank Secrecy Act at Title 31, U.S. Code Section 5311-5340.

This placement of Section 221 in the USA Patriot Act gives economic and trade sanctions a relationship to the act’s AML and counter-terrorism provisions and underscores the important role of sanctions as tools of U.S. foreign policy, diplomacy and international relations. (March 28, 2016)

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