Extraterritorial Application of the USA PATRIOT Act and Related Regimes: Issues for European Banks Operating in the United States, Privacy & Data Security Law Journal
Published in the October 2007 Privacy & Data Security Law Journal. Copyright ALEXeSOLUTIONS, INC.
The authors review the background and scope of the USA PATRIOT Act and discuss the interplay of the anti-money laundering statutes and regulations and the combat of terrorist financing provisions with the U.S. financial sanctions regimes.
The authors also highlight the resulting legal issues affecting the business operations of foreign banks, especially those headquartered in the Member States of the European Union with substantial business interests in the United States, and explain that the issues largely center around correspondent account transactions and clearing issues as well as home and host country compliance conflicts resulting from significant differences between EU and U.S. boycott and data protection regimes.
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