The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Pub. L. No. 107-56 (the "Patriot Act" or "Act") was signed into law on October 26, 2001, by President Bush. Title III of the Act, the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, enacts anti-money-laundering provisions covering financial institutions. The United States Treasury Department (the "Treasury") has authority to promulgate rules and regulations required to implement the Act.

On September 18, 2002, pursuant to this authority, the Treasury proposed a rule, requiring "unregistered investment companies," to adopt and implement anti-money-laundering compliance programs within ninety days following publication of the final rule. The final rule is expected some time during the first quarter of 2003. Following adoption of the rule, failure to implement a program may result in severe civil or criminal penalties.