The US Framework II — USA PATRIOT Act §§311–319 *(OUTLINE + BULLET BODY)*

After September 11th, 2001, US lawmakers looked at the Bank Secrecy Act and decided it wasn't enough. Within six weeks they passed the USA PATRIOT Act, and Title III of that law — the International Money Laundering Abatement and Financial Anti-Terrorism Act — rewired American AML. The CAMS® exam tests this as a matching game: it gives you a section number and asks what it does, or describes a requirement and asks for the section. The danger zone is the 300s — sections 311 through 319 — because they all sound similar. So let's give each one a sharp, memorable identity you won't mix up under exam pressure.

- USA PATRIOT Act passed **October 2001**; **Title III** is the AML title, which **amended the BSA**. - The 300s are special-measures and due-diligence provisions aimed at international money laundering, correspondent banking, and information sharing. - Memory hook for the order: **311 = special measures, 312 = EDD on foreign correspondents & private banking, 313 = no shell banks, 314 = sharing, 319 = forfeiture/records.**

- Authorizes the **Secretary of the Treasury (via FinCEN)** to designate a foreign jurisdiction, institution, class of transaction, or type of account as a **"primary money laundering concern."** - Once designated, Treasury can impose one or more of **five graduated "special measures"** — ranging from extra recordkeeping/reporting on the targeted activity up to the most severe: **prohibiting US financial institutions from opening or maintaining correspondent accounts** for the designated entity. - The fifth special measure effectively cuts the target off from the US financial system. It's a targeted, surgical tool — not a blanket sanction. - Exam cue: "**primary money laundering concern**," "five special measures," "Treasury/FinCEN designation."

- Requires US financial institutions to apply **due diligence**, and in higher-risk cases **enhanced due diligence (EDD)**, to: - **Correspondent accounts** maintained for **foreign financial institutions**, with **enhanced** scrutiny for correspondents in jurisdictions of concern, offshore banks, or banks lacking adequate supervision; and - **Private banking accounts** maintained for **non-US persons**. - For **private banking accounts** ($1,000,000+ aggregate threshold in the rule), the institution must take **reasonable steps to identify the nominal and beneficial owners** and the source of funds, and apply **enhanced scrutiny** where a **senior foreign political figure (PEP)** is involved — to detect and report proceeds of foreign corruption. - Exam cue: "**enhanced due diligence on foreign correspondent accounts and private banking for non-US persons**," "source of funds," "senior foreign political figures."

- **Prohibits** US financial institutions from establishing, maintaining, or managing **correspondent accounts for foreign shell banks** — banks with **no physical presence** in any country and not affiliated with a regulated financial institution. - Institutions must take reasonable steps to ensure correspondent accounts are not being **indirectly** used by shell banks. - Pairs with §319(b)'s requirement that the foreign correspondent identify its owners and a US agent for service of process. - Exam cue: "**no shell banks**," "no physical presence," "correspondent account prohibition."

- **§314(a) — government-to-institution.** Law enforcement, **through FinCEN**, sends financial institutions the names of persons **suspected of money laundering or terrorist financing**. Institutions must **search their records** for accounts or transactions and report **matches** back to FinCEN (generally within **14 days**). It is mandatory to search; direction flows **government → FI**. - **§314(b) — institution-to-institution (voluntary).** Financial institutions may **voluntarily share information with each other** to identify and report potential money laundering or terrorist financing. Participation requires **registration with FinCEN** and provides a **safe harbor** from liability for sharing in good faith. Direction is **FI ↔ FI**, and it is **optional**. - Memory hook: **314(a) = Authorities ask (and you must search); 314(b) = Between Banks (and it's voluntary).** - Exam cue: don't swap them. If the question says "government list, mandatory search," it's 314(a). If it says "two banks share voluntarily with safe harbor," it's 314(b).

- **§319(a) — forfeiture from correspondent accounts.** If laundered funds are deposited in a **foreign bank** that holds a **correspondent account** at a **US bank**, US authorities may seize the equivalent funds from the **US correspondent account** — without having to trace the specific dollars overseas. It gives reach into funds that would otherwise be beyond US jurisdiction. - **§319(b) — records of correspondent accounts.** Requires that a foreign bank with a US correspondent account identify its **owners** and a **US agent for service of legal process (subpoenas)**, and US institutions must keep these records and be able to produce them, generally within **7 days** of a request. - Exam cue: "**forfeit from the US correspondent account**" (319a); "**foreign bank's owners + US agent for subpoenas**" (319b).

- **§311** → special measures; designate "primary money laundering concern"; up to 5 measures. - **§312** → EDD on **foreign correspondent** accounts and **private banking** for non-US persons; source of funds; PEP scrutiny. - **§313** → **prohibits** correspondent accounts for foreign **shell banks**. - **§314(a)** → **government → FI** name searches via FinCEN (mandatory; ~14 days). - **§314(b)** → **FI ↔ FI** voluntary sharing with **safe harbor** (register with FinCEN). - **§319(a)** → forfeiture reachable through the **US correspondent account**. - **§319(b)** → foreign correspondent must name **owners + US agent**; produce records (~7 days). - (Also worth knowing: **§326** is the Customer Identification Program (CIP) requirement — we cover CIP/CDD in Domain 3.)

So here's your matching key for the 300s. Three-eleven names a primary money-laundering concern and imposes special measures. Three-twelve is enhanced due diligence on foreign correspondent and private banking accounts. Three-thirteen bans shell banks. Three-fourteen-a is the government asking you to search names; three-fourteen-b is banks voluntarily sharing with each other under a safe harbor. And three-nineteen lets authorities forfeit through the US correspondent account and demand the foreign bank's owners and a US agent. Practice the section-to-rule mapping until it's automatic. Next, we move to the modern layer of US AML: the FinCEN Customer Due Diligence Rule, the Anti-Money Laundering Act of 2020, and the Corporate Transparency Act — including the twenty-five-percent beneficial-ownership test and beneficial-ownership-information reporting.