What action does the USA PATRIOT Act allow the US government to take regarding financial institutions (FIs) that are based outside of the US?

Section 319(b) of the USA PATRIOT Act grants the US Attorney General or the Secretary of the Treasury the authority to issue a subpoena or summons to any foreign bank that maintains a correspondent account in the United States. This power extends to records held outside the US related to that account. If the foreign bank fails to comply with the subpoena, the US correspondent bank is required to terminate its relationship, effectively cutting the foreign bank off from direct access to the US financial system.

A: Sanctioning an entire country is a major geopolitical action, not a direct, standard response to a single FI's non-compliance under the PATRIOT Act. C: The US government lacks the sovereign authority to revoke a banking license that has been granted by another country's regulatory body. D: The Office of Foreign Assets Control (OFAC), not "all US regulators," manages the SDN list, and designation is based on specific national security criteria.

1. ACAMS CAMS6-EN Study Guide, Chapter 3: International AML/CFT Standards, (2020), p. 138. "Section 319(b) of the Patriot Act allows the US Treasury Secretary or Attorney General to subpoena a foreign bank that maintains a correspondent account in the US... for any records relating to the correspondent account."

2. Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT) Act of 2001, Pub. L. No. 107-56, § 319(b).