Further Guidance on President Bush's Executive Order Freezing Assets that Support Terrorism
October 9, 2001
TO THE CHIEF EXECUTIVE OR OPERATING OFFICER OF THE BANKING INSTITUTION OR LICENSED MONEY TRANSMITTER ADDRESSED
We have previously advised you of the issuance of the Presidents Order freezing assets of individuals and organizations that support terrorism. This letter provides further guidance to your efforts to comply with the Order, which I would emphasize once again is vitally important.
Specifically, it is strongly recommended that institutions and licensees receiving monies for transmission should follow best industry practices in attempting to comply with the Order. To ensure such compliance, it is strongly recommended that such practices include obtaining additional identifying information from any person(s) seeking such money transmission services, either for themselves or on behalf of any entity. This information should include, at a minimum, at least the date of birth of such persons, which should be verified by a drivers license or other official document.
For similar reasons, it is strongly recommended that institutions and licensees receiving monies for transmission obtain as much of the following information as possible regarding the beneficiaries of the transfer, including their: (1) date of birth; (2) drivers license number; (3) passport number; (4) national identification number, if applicable; and (5) any other information usually obtained for such persons by the transmitter.
All of this information should be retained by your institution or licensee until further notice. Licensees also should communicate this guidance to all of their agents and subagents.
Should you have any questions regarding this Guidance letter, please contact Investigative Counsel Irwin Nack at (212) 618-6601.
Very truly yours,
Superintendent of Banks