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Until September 11, 2001, the predominant focus of the BSA was on curtailing the use of the U.S. financial system for purposes of drug trafficking. The passage of the Patriot Act in October 2001 expanded the application of the BSA to terrorist financing and reinvigorated banks' BSA compliance efforts. But while most bank executives focus their BSA compliance efforts on areas such as branch operations, wire transfers, and cash management, the lending area is also ripe with risk and opportunity for potential abuse.

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