Although there is no published guidance on how Financial Institutions should comply with this forthcoming requirement, the Department of the Treasury must submit to Congress the results of a study on how best to verify the identify of foreign nationals and check customer databases for known or suspected terrorists. In addition, the proposed regulations published at the end of last year concerning due diligence for private banking accounts and correspondent accounts may also provide some useful guidance for investment companies preparing to implement identification verification procedures. 13
The Intelligence to Prevent Terrorism Act was introduced to the Senate on September 28 by Senators Bob Graham ( D - FL ) and Jay Rockefeller ( D - WV ).  The bill proposed a number of changes relating to the Director of Central Intelligence (DCI). The most significant change proposed was to require the Attorney General or head of any other Federal department or agency to disclose to the DCI any foreign intelligence acquired in the course of a criminal investigation. However, it would also have required that the DCI and Secretary of the Treasury jointly report to Congress as to whether it would be a good idea to reconfigure the Office of Foreign Assets Control and its Foreign Terrorist Asset Tracking Center to provide for the analysis and dissemination of foreign intelligence relating to the financial capabilities and resources of international terrorist organizations. It would also have required the DCI to establish and maintain a National Virtual Translation Center  for timely and accurate translations of foreign intelligence for elements of the intelligence community. Another area it covered was a proposal to make the Attorney General provide a program of training to Government officials regarding the identification and use of foreign intelligence.  
Until the . government releases more information about the uses it might make of its Patriot Act powers, it will be difficult to determine how worried Canadian businesses should be and what should be done to protect the personal information of Canadians in the hands of .-linked companies. In the meantime, by ensuring that clients are aware of when and how their information may be at risk of access by . authorities, and by exploring other means of contractually protecting the data, Canadian CAs and their firms can help protect themselves to some degree from breaches of Canadian privacy legislation.