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717 Second Street NE * Washington, DC 20002 * (202) 546-3000 * Fax (202) 543-5605
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May 15, 2001<\/p>\n
The Honorable Paul H. O’Neill
Secretary of the Treasury
1500 Pennsylvania Ave NW
Washington, DC 20220<\/p>\n
Dear Secretary O’Neill:<\/p>\n
The undersigned organizations, representing a diverse and broad cross-section of American society, are concerned that the Administration is not adequately safeguarding privacy in the context of certain international initiatives in the area of investigations regarding financial crimes. Specifically, we are concerned that the proposals of the Organization for Economic Cooperation and Development (OECD) and the Financial Action Task Force (FATF) for increased bank reporting on customers do not respect our financial privacy.<\/p>\n
We recognize your increased concern for the tax implications with the OECD and the FATF but are concerned that you have not made privacy a sufficient priority. The current proposals of OECD and FATF attempt to institute the popularly rejected “Know Your Customer” financial regulation, thereby sidestepping the domestic legislative process. We are concerned about the attempt to get Know Your Customer adopted as an international “best practice” under the guise of increasing transparency.<\/p>\n
Over 300,000 citizens filed comments against the Know Your Customer proposal under the Clinton Administration. We are disappointed that the Bush Administration continues to pursue an approach that Larry Lindsey has described as ineffective: 99.999% of all Currency Transaction Reports filed are on law-abiding citizens going about their normal business. The Suspicious Activities Reports’ approach discriminates against the poor, as well as racial and ethnic minorities.<\/p>\n
The OECD and FATF’s campaigns against banking secrecy and “harmful tax competition” are problematic for several reasons. This approach undermines the public confidence between individuals and their financial institutions, accountants and lawyers. These policies would likely distort capital inflows to the United States and could act, effectively, as capital controls. Economic dislocations to affected countries could lead to unintended political, foreign policy and immigration concerns. Our modern economy requires a liberal capital policy that engenders the consumer trust that comes with respect for privacy. We strongly urge you to make a clear statement instituting policies that respect financial privacy and that the Treasury Department opposes the type of reporting requirements being advanced by the OECD and FATF.<\/p>\n
Respectfully,<\/p>\n