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USA PATRIOT Act: Report to Congress on application to investment companies.

The signatures on the covering letter (strangely undated) sent to Congress are immediately striking: Greenspan, O'Neill and Pitt. The report is dated 31 December 2002 and that is the date it was released. Presumably, then, that is the date that should have been on the letter.

But after all the fuss about their removal or resignations (depending on whose version of events turns out to be correct) it is a surprise to see Pitt and O'Neill's names on documents today.

The report, at its outset, shows the continuing failures to meet the deadlines set out in the USA PATRIOT Act. The Act, at s356, requires the making of the Report within one year of enactment. It should have been presented before 26th October 2002. So the report is more than two months late.

The first section of the report provides a useful history of the development of federal counter-money laundering law. The second part of the report is a useful roundup of various types of investment vehicle and, to a limited extent, the

The report cross refers to the rules proposed in July 2002.

The report discloses nothing novel - but it serves an important purpose in restating the obvious (denied by some) that investment companies are obvious targets for money launderers. However, there is an interesting sidelight on the problems relating to "hedge funds:" the report says "no official reporting organisation exists for hedge funds." This reflects the generally low level of regulation that applies to such ventures, often set up in such a way as to be, in effect, a private club. Things are changing.

But the report quotes the proposed rules' bizarre description of low risk: businesses with less than USD1 million in assets would be exempt much of the compliance regime as they are "small businesses" and "unlikely to be used for money laundering. How

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