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From:cromwell@sullcrom.com
To:legal <.taylor@enron.com<
Subject:S&C Memo Re: Treasury Department Interim Guidance on Compliance w
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Date:Fri, 23 Nov 2001 15:46:44 -0800 (PST)

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Re: Treasury Department Interim Guidance on Compliance
with Sections 313 and 319(b) of the USA PATRIOT Act


Attached is a memorandum from Sullivan & Cromwell concerning the above subject. A summary is also included at the end of the text of this e-mail message.

The attached file is in Adobe Acrobat format.
We believe most PCs will already have an Acrobat viewer loaded; we can provide free copies if Acrobat is not already loaded, and
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format. Hard copies can be obtained from Ivy Moreno at S&C in New York, telephone 212-558-3448, e-mail: Morenoi@sullcrom.com.


SUMMARY

Two anti-money laundering provisions of the USA PATRIOT Act, sections 313 and 319(b), become effective on December 25, 2001. Late Tuesday, the Treasury Department announced interim guidance (the ''Interim Guidance'') for banking institutions on compliance with those sections. The

Interim Guidance is based on a certification that would be submitted by foreign respondent banks to their U.S. correspondent banks.






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