The USA Patriot Act contained significant regulatory efforts to implement the anti-money laundering provisions. Since the Patriot Act's hasty passage after September 11, regulators and industry have been working overtime to meet the required deadlines.

Primary oversight for the Patriot Act falls under the Treasury Department, which has issued several regulations implementing various provisions within the Act. These include:

• A proposed rule to require broker-dealers to file "suspicious activity reports" ("SARs") with the Financial Crimes Enforcement Network ("FinCEN") for all suspicious transactions that are "conducted or attempted by, at or through" a broker-dealer that involve at least $5,000 in funds or assets;

• A proposed rule to require financial institutions to respond to requests from Treasury for information concerning persons or entities suspected of terrorism or money laundering;

• An interim rule authorizing some financial institutions—principally those that have SAR obligations—to share such information among themselves; and

• A rule that would bar banks and broker-dealers from offering "correspondent accounts," directly or indirectly, to foreign "shell banks," and require banks and broker-dealers that provide correspondent accounts to any foreign bank to maintain records of the ownership of such foreign bank and its agent in the United States for service of process.