House Banking letter to FDIC on Know Your Customer regs (Declan McCullagh) LONG!greenspun.com : LUSENET : TimeBomb 2000 (Y2000) : One Thread
# # # 19981231--House Banking letter to FDIC on Know Your Customer regs
These regs would put a real crimp in legitimate Y2K preparations.
LONG ... but worth the read ... Regards, Bob Mangus # # #
[Forwarded via Scan this News. I've also attached an analysis by Larry Becraft.My article from a few weeks ago:
December 18, 1998
Robert E. Feldman, Executive Secretary, Comments/OES Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429
Dear Mr. Feldman,
While we are pleased to learn your agency has decided to delay implementation of this proposed "Know Your Customer" rule, and then apply it only to new accounts, we members on the House Committee on Banking and Financial Services still oppose the draft regulation. First, it is our desire to ensure that any new regulation accomplishes only legitimate and necessary law enforcement purposes without violating the privacy rights of customers. Secondly, we are opposed to any regulation that forces needless and expensive unfunded mandates on financial institutions.
In addition to consumer privacy concerns, the "Know Your Customer" draft rule would undermine the relationship between the financial institution and the client. The unofficial "profiling" of transactions that are not "regular and expected" may discriminate against the poor (who are more likely to be unbanked) as well as racial and ethnic minorities (some of whom use cash more for cultural reasons).
Because the financial institution is already held accountable for tracking and reporting any "suspicious" transactions to the regulators, any alleged benefits of this proposed rule would be outweighed by the additional cost. This rule essentially deputizes tellers not only as law enforcement agents but private investigators as well. We are concerned that the financial institution lacks an adequate safe harbor from liability and that the customer is presumed guilty of suspicious behavior until proven innocent.
The cost of these proposed financial regulations would be excessive. Financial institutions will attempt to impose the increase on their customers through higher rates and new or higher fees. According to the Financial Crime Enforcement Network (FinCEN), the compliance costs in 1996 amounted to over $83 million for just the Bank Secrecy Act. This act is part of the estimated, aggregate cost of financial institution regulation (noninterest expenses) on commercial financial institutions totalling $125.9 billion in 1991, according to an April 1998 Fed Staff Study. Moreover, the new regulations will impose a disproportionately large cost on smaller institutions because larger institutions have a comparative advantage in internalizing the cost of compliance of additional regulation. This inherent advantage for larger institutions would contribute to the further consolidation of assets in the financial system. Efforts must be made to reduce--not increase--the regulatory compliance costs, especially for smaller institutions.
It is our hope that the resolution of this matter will not require legislative action.
Ron Paul Bob Barr
Tom Campbell Frank Lucas
Bob Ehrlich Jim Ryun
Merrill Cook Vince Snowbarger
Bob Riley Pete Sessions
Walter Jones Bill Redmond
cc: Jennifer Johnson, Board of Governors of the Federal Reserve System; Communications Division (Docket No. 98-15), Office of Comptroller of the Currency; Manager Dissemination Branch (Docket No. 98-114), Office of Thrift Supervision.
Date: Tue, 29 Dec 1998 20:02:43 -0600 From: Larry Becraft
To: firstname.lastname@example.org Subject: KYC regs
Dear Declan, Saw a forwarded note you wrote about the KYC regs. The feds are full of crap when they claim that the objectors have made no substantive objections. Mine points out that the proposal simply lacks a statutory foundation and consequently is void. See attached letter. It is in WP but I can send in Word. Larry Becraft
December 8, 1998
Mrs. Jennifer J. Johnson, Secretary Board of Governors of the Federal Reserve System 20th and Constitution Avenue, N.W. Washington, D.C. 20551 Re: Comments to Docket No. R1019: Proposed rules to be codified at 12 C.F.R., Parts 208, 211 and 225.
Dear Mrs. Johnson,
On Monday, December 7, 1998, the Board of Governors proposed a group of new regulations collectively referred to as the 'Know Your Customer' program and requested comments thereto. Please consider this letter as my comments and suggestions for modification of these proposed rules.
A. Introduction to Comments.
Western civilizations, and particularly here in our country, have a tradition of liberty and freedom for the people. Western governments, and especially ours, protect these popular liberties by presuming the people to be law abiding and any given individual can only be criminally investigated when there is probable cause to do so; here in America, this procedure is constitutionally memorialized. This approach to law enforcement stands in sharp contrast with that of totalitarian societies, most of which are communist, where government inherently distrusts the people and subjects them to draconian measures. The society in which I and many others desire to live is this American one, which follows this governing philosophy: the greatest good for the greatest number of people is that they be free.
Powerful forces in the world today seek to unify the nations of the earth in a world government, and clearly those leading this effort are confronted with these polar opposites in governing philosophies between free and totalitarian states. The natural question which arises for outsiders such as myself is which governing philosophy will be adopted by the architects of world government. Since we who are outside the pinnacles of power are not involved in this decision making process, we can only observe and draw conclusions based upon concrete facts.
Recent history reveals two tyrannical forms of government which mankind must be Mrs. Jennifer J. Johnson December 8, 1998
ever vigilant to resist: Hitler's Nazi Germany and Stalin's Communist Russia. In Germany prior to and during WWII, Hitler's Brown Shirts and his Gestapo built their base of power by first spying upon the people and developing profiles of every individual. Through these dossiers of everyone, the Nazis identified all the Jews and eventually rounded most of them up for that final trip to the death camps. Little known is the fact that many who were not Jews but only opponents of the prevailing form of government suffered the same fate. A similar occurrence happened in the Stalinist Soviet Union. The Bolsheviks spied upon the people and likewise developed profiles for the express purpose of determining who was friend or foe. During Stalin's great purges of the early thirties, he liquidated even his friends, which indicates that even profiles can be wrong.
These two governments brought untold misery not only to the peoples they ruled but also the rest of humanity. They ultimately challenged the entire world, caused war and consigned to death literally hundreds of millions of people. I do not need to express here the consequences of such forms of government as Prof. Ruddy Rummel's fine work, Death by Government, gruesomely does so. If you are on the Internet, I strongly encourage you to read his webpage located at:
But please remember: the first indicator of a tyrant is his desire to profile the people. It is anti-human for government to build personal dossiers.
It appears to me that those who seek world government are listening, either wittingly or unknowingly, to modern day Nazis and Communists. In 1989 at a G-7 summit meeting in Paris, the Financial Action Task Force ('FATF') was created for the purpose of establishing programs to combat international drug running and money laundering. On April 28, 1998, at the Organisation for Economic Development and Cooperation meeting in Paris, FATF proposed that '[e]ach country should take immediate steps to ratify and to implement fully the 1988 United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (the Vienna Convention).' With ratification of this treaty, FATF suggested that states adopt an 'effective money laundering enforcement program,' the American version of which is the 'Know Your Customer' program.
Surely, fighting drug trafficking is a laudable goal, but such a battle must be focused upon the real criminals instead of the law abiding populace at large. Indeed, this is the manner in which we traditionally fight crime here in America, and this method protects the liberties of the people. But in the East where the Nazis and Communists were born, law enforcement methods are the opposite in nature, and they are antithetical to our form of government. These types of government as noted earlier distrust the people and they Mrs. Jennifer J. Johnson December 8, 1998
consequently spy upon them. The 'Know Your Customer' program not only represents a fundamental shift in the emphasis of law enforcement toward the form prevalent in dictatorships, but it is also the first step (and a major one at that) in the erection of an American spy network. Although couched in the terms of an unalarming name, the 'Know Your Customer' program is first and foremost a dossier building program, and the introduction for the proposed rules states as much ('Effective 'Know Your Customer' programs will necessarily require that banking organizations develop 'customer profiles,''63 Fed. Reg. at 67517). The design of these profiles is to monitor ' the legitimate activities of [banking] customers' (63 Fed. Reg. at 67516).
Worldwide, the wishes of FATF are being heeded by government heads, presidents of central banks and the leaders of domestic and international banking institutions. Pursuant to FATF suggestions, a global project is now underway to implement surveillance of the financial transactions of every living person on earth; soon a wide variety of other personal information kept in computerized systems of records will be combined with the financial to produce the perfect profile of any particular individual. History proves that nations have fallen and suffered tremendous ruin by the implementation of such a spy network. However in this instance, the consequences are slightly different because this is not a national spy network but a global one. This worldwide system will have global consequences and if history means anything, the predictable tragedy will be global.
Please pardon me, but I have a moral obligation to strenuously object to this national 'Know Your Customer' program which is a part of a global spy network.
B. The Proposed Rules Lack a Statutory Foundation.
It is an established principle of law that one may not be required to supply information unless the applicable statute requires that the information be supplied. For example, in Viereck v. United States, 318 U.S. 236, 242, 63 S.Ct. 561, 563-64 (1943), a foreign agent who omitted certain information from his foreign agent's registration statement was prosecuted because the government believed he should have disclosed some information which he did not. In reversing that conviction, the Supreme Court held: "Unless the statute, fairly read, demands the disclosure of the information which petitioner failed to give, he cannot be subjected to the statutory penalties."
See also United States v. Irwin, 654 F.2d 671, 679 (10th Cir. 1981)("And, of course, there can be no criminal conviction for the failure to disclose when no duty to disclose is demonstrated"); United States v. Anzalone, 766 F.2d 676, 683 (1st Cir. 1985); United States v. Larson, 796 F.2d 244, 246 (8th Cir. 1986); and United States v. Dorey, 711 F.2d 125, 128 Mrs. Jennifer J. Johnson December 8, 1998
(9th Cir. 1983). Agency regulations which have no statutory foundation are void; see City of Tucson v. C.I.R., 820 F.2d 1283 (D.C.Cir. 1987). Agencies do not have unbridled authority to adopt whatever regulations they wish; see Gutknecht v. United States, 396 U.S. 295, 306, 90 S.Ct. 506 (1970) ("The power under the regulations to declare a registrant 'delinquent' has no statutory standard or even guidelines. The power is exercised entirely at the discretion of the local board. It is a broad, roving authority, a type of administrative absolutism not congenial to our law-making traditions").
The Federal Reserve Board's proposed 'Know Your Customer' program seeks to amend 12 C.F.R., parts 208, 211 and 225 by adding several new sections. For part 208, the preface to the proposed rules declares that the statutory authorities for them are as follows: 12 U.S.C., ''24, 36, 92a, 93a, 248(a), 248(c), 321338a, 371d, 461, 481486, 601, 611, 1814, 1816, 1818, 1823(j), 1828(o), 1831o, 1831p1, 3105, 3310, 33313351, and 39063909; 15 U.S.C., ''78b, 78l(b), 78l(g), 78l(i), 78o4(c)(5), 78o5, 78q, 78q1, and 78w; 31 U.S.C., '5318; and also 42 U.S.C., ''4012a, 4104a, 4104b, 4106, and 4128. For part 211, the statutory authorities are asserted to be 12 U.S.C., ''221, et seq.; ''1818, 1835a, 1841, et seq.; ''3101 et seq.; and ''3901 et seq. For part 225, the statutory foundation for the new rules are claimed to be 12 U.S.C., ''1817(j)(13), 1818, 1828(o), 1831i, 1831p1, 1843(c)(8), 1844(b), 1972(l), 3106, 3108, 3310, 33313351, 3907, and 3909. I will not summarize each of these sections, but I will inform you that I have examined each one. These statutes (excluding 31 U.S.C., '5318) have nothing within them which could in any way support the program which is the subject of the proposed rules. Consequently, all of the above mentioned statutes cited by these proposed regulations simply do not provide the statutory foundation for this program.
But, the preface does mentions one specific section of the currency transaction reporting laws codified at 31 U.S.C., ''5311, et seq., as statutory support for these proposed new rules. These CTR laws deal almost exclusively with currency deposits and withdrawals, and the reporting of such transactions by banks; but they simply do not provide a legislative command that bank customers should be profiled and monitored for normal and abnormal transactions, even by checks. The only statute which might arguably support this program is 31 U.S.C., '5318(g), which is indeed mentioned in the preface. It provides as follows: '(g) Reporting of Suspicious Transactions. '(1) In general. The Secretary may require any financial institution, and any director, officer, employee, or agent of any financial institution, to report any suspicious transaction relevant to a possible violation of law or regulation.'
Clearly, the operative word in '5318(g) is 'suspicious,' which is the very heart of this scheme. However, this word is extremely vague, making this statute potentially void; see Mrs. Jennifer J. Johnson December 8, 1998
City of Columbus v. Thompson, 25 Ohio St.2d 26, 266 N.E.2d 571 (1971); and Kolender v. Lawson, 461 U.S. 352, 103 S.Ct. 1855 (1983).
Courts have determined the meaning of 'suspicious' and 'suspicion' and found these words unlawfully vague. For example, in Leonardo v. State, 728 P.2d 1252, 1256 (Colo. 1986), that court noted that '[s]uspicion does not rise to the level of belief or knowledge... It encompasses the apprehension of something without proof or upon little evidence.' In Lachs v. State, 366 So.2d 1223, 1226 (Fla.App. 1979), that court noted that '[m]ere suspicion is no better than random selection, sheer guesswork, or hunch, and has no objective justification.' Being vague and having no definite parameters, '5318(g) appears not only unconstitutional, but it also allows agencies such as yours to engage in unauthorized legislation by rulemaking.
An example of legislation by rulemaking is found in a current rule which implements '5318(g). The 'suspicious transactions' regulation codified at 12 C.F.R. '353.3, requires financial institutions to report some transactions of $5000, and all transactions of $25,000, apparently because these completely arbitrary numbers are 'suspicious.' Because of the vagueness of the word 'suspicious' and its lack of a statutory definition, this word apparently means anything a federal agency such as yours wants it to mean. Perhaps I am just a dense country lawyer, but how the requirements of '353.3 assist in the reporting of potential violations of the law or regulations simply defy logic. Why is a $24,990 transaction not suspicious, but one only $11 more is? But then again, a $5001 transaction might be suspicious but a $24,990 is not. Simply stated, '353.3 is completely arbitrary and that arbitrariness arises from the vagueness of the word 'suspicious.' Because this word is unconstitutionally vague, the demands of '353.3 have absolutely nothing to do with transactions which might be illegal; and it clearly appears that the sole purpose of '353.3 is to assist government spying upon legitimate financial transactions of the American people. I mention this problem because I wish to preserve a constitutional challenge to 31 U.S.C., '5318(g), and any new regulations based thereon.
But the argument that '5318(g) does not support the Board's 'Know Your Customer' program is no invention on my part. At the same time that the Board's proposed rules were published in the Federal Register, similar proposed rules were also published by the FDIC. In the introductory comments for the FDIC's proposed 'Know Your Customer' program, it described the program as requiring nonmember banks 'to identify their customers, determine their customers' normal and expected transactions, determine their customers' sources of funds, monitor transactions to find those that are not normal and expected, and, for transactions that are not normal and expected, identify which are suspicious,' 63 Fed.Reg. 67534. Requiring financial institutions to perform these various acts should be the subject of legislation and not agency rulemaking. But, the FDIC admitted in its publication that Mrs. Jennifer J. Johnson December 8, 1998
'[u]nder current law, financial institutions are required to report suspicious activities to law enforcement authorities, but are not required to specifically search for suspicious activities. As a result, suspicious activities may go unreported, and illegal activity may go undetected,' 63 Fed.Reg. 67533. I consider this statement by another federal supervisory agency to be an admission; see United States v. Van Griffin, 874 F.2d 634, 638 (9th Cir. 1989)(government manuals admissible as party admissions under Fed.R.Evid. 801(d)(2)(D)); and United States v. GAF Corp., 928 F.2d 1253 (2nd Cir. 1991). Clearly, these requirements to specifically search for 'suspicious activities' is without any legal foundation.
I would suggest that you study the development of the CTR regulations and how the courts responded to them. Initially, there was no legal support for the requirement of not structuring cash transactions; see United States v. Anzalone, 766 F.2d 676, 681, 682 (1st Cir. 1985); United States v. Denemark, 779 F.2d 1559 (11th Cir. 1986); United States v. Varbel, 780 F.2d 758, 762 (9th Cir. 1986), United States v. Dela Espriella, 781 F.2d 1432 (9th Cir. 1986), and United States v. Larson, 796 F.2d 244 (8th Cir. 1986). Because the courts determined that structuring was not illegal, Congress was required to adopt anti-structuring laws. Similarly, imposing new demands upon financial institutions to look for ill defined 'suspicious transactions' can only be achieved through congressional action, not agency 'legislation.' I suggest that you withdraw these proposed regulations and seek legislative approval from Congress.
C. The Proposed Rules Violate Other Federal Law.
The Board's introductory remarks to the proposed rules state their purpose: 'This paragraph (d) requires that member banks establish and regularly maintain procedures reasonably designed to determine the identity of their customers, as well as their customers' normal and expected transactions and sources of funds involving the bank' (63 Fed. Reg. 67523). Abnormal transactions are those which are not normal; abnormal transactions are apparently suspicious, which means that they are reported to law enforcement and the records of such transactions must be made available within 48 hours of request. These rules envision that financial institutions will detect abnormal, 'suspicious' transactions which in the words of the Leonardo court will simply be 'apprehension[s] of something without proof or upon little evidence,' and these apprehensions are to be reported to law enforcement. The carrot is thus being dangled out in front of law enforcement, and it is only natural to expect it to take the bait.
In United States v. Miller, 425 U.S. 435, 443, 96 S.Ct. 1619, 1623 (1976), the Supreme Court held that individuals have no Fourth Amendment expectation of privacy in their financial records while those records are in the hands of third parties. In response to this decision, Congress adopted the financial privacy provisions codified in 12 U.S.C., ''3401, Mrs. Jennifer J. Johnson December 8, 1998
et seq., which limit access to financial records held by a bank. Under these laws, federal agencies may obtain banks records only via subpoena or judicial process.
The proposed rules ignore the mandates of 12 U.S.C., ''3401, et seq. My experience with law enforcement leads me to the conclusion that unless the new rules contain some provision noting the limits Congress has placed upon the ability to obtain records such as these, those limits will be ignored. Under these rules, it is easy to expect that some federal law enforcement agents will believe that compliance with the privacy laws is no longer needed and that the requirements of 'probable cause' may be discounted. There are lawyers here in America waiting for such opportunities to sue banks in situations like this; see Lopez v. First Union National Bank of Florida, 129 F.3d 1186 (11th Cir. 1997). If your agency really has an interest in protecting banks from suits like this, I strongly suggest that you remind federal law enforcement about the privacy laws in the body of the new regulations.
D. The Proposed Regulations Are UnAmerican.
As noted previously, programs like 'Know Your Customer' were developed at the suggestion of the FATF. But FATF is not a legislative body for any part of the United States, and only Congress may adopt federal laws. But Congress has not enacted any law that mandates banks to spy upon their customers legitimate banking transactions and to build financial dossiers which are available to law enforcement.
In recent years, it has been apparent that a number of federal agencies have been listening to the desires of the international community and not that of Congress. Agency officials attend these international meetings and return with their heads full of these international ideas, many of which are alien to American society. Using their rulemaking powers, these agencies then circumvent Congress and adopt rules to implement these international schemes. It must be noted, however, that such a process is not only illegal, but also unconstitutional.
Under the United States Constitution, the Senate possesses the treaty ratifying power. Once a treaty is ratified, Congress as a whole adopts laws to implement those treaties. For example, our country has ratified a wide variety of treaties covering such matters as drugs, endangered species, wetlands, fishing, wildlife, communications, air traffic and a number of other matters. When the Senate approves any given treaty, Congress itself decides the precise legislative scheme which will be used to implement the treaty. This power is possessed only by Congress and not its creatures such as the Board. However in this instance, your 'Know Your Customer' program lacks a statutory foundation, which means that Congress has yet to decide how it plans to implement the 1988 Vienna Convention. The absence of a statutory foundation for this program obviously means that the Board is taking its orders from the Mrs. Jennifer J. Johnson December 8, 1998
FATF and directly implementing an international program without Congressional approval, which is illegal and unAmerican.
But further, the American people are accustomed to financial privacy and this tradition is protected by a number of federal and state laws. Of course, drug trafficking is a problem, but the entire American populace is not involved with either this activity or anything else illegal. The 'Know Your Customer' program seeks to examine financial records of law abiding citizens for no other reason than that your agency is just curious. Businessmen of all types have business receipts which fluctuate from month to month and year to year. Ordinary citizens frequently purchase and sell property such as cars and homes. Yet under this proposed program, a businessman who buys a new facility or a wage earner who sells a car or buys a home will likely be visited by law enforcement asking lots of curious and stupid questions. Frankly, the American people have every right to complain about this unwarranted spying which has nothing to do with finding drug dealers, and everything essential to building a police state.
Perhaps Justice Douglas' observations in Laird v. Tatum, 408 U.S. 1, 28-29, 92 S.Ct. 2318, 2333 (1972), are particularly appropriate here: "This case involves a cancer in our body politic. It is a measure of the disease which afflicts us. Army surveillance, like Army regimentation, is at war with the principles of the First Amendment. Those who already walk submissively will say there is no cause for alarm. But submissiveness is not our heritage. The First Amendment was designed to allow rebellion to remain as our heritage. The Constitution was designed to keep government off the backs of the people. The Bill of Rights was added to keep the precincts of belief and expression, of the press, of political and social activities free from surveillance. The Bill of Rights was designed to keep agents of government and official eavesdroppers away from assemblies of people. The aim was to allow men to be free and independent and to assert their rights against government. There can be no influence more paralyzing of that objective than Army surveillance. When an intelligence officer looks over every nonconformist's shoulder in the library, or walks invisibly by his side in a picket line, or infiltrates his club, the America once extolled as the voice of liberty heard around the world no longer is cast in the image which Jefferson and Madison designed, but more in the Russian image..."
By striking the phrase 'Army surveillance' from Justice Douglas' profound comments and inserting the phrase 'banking surveillance' the correct image emerges. The 'Know Your Customer' program seems to have been concocted after some bureaucrat finished reading his favorite books, Marx's Das Kapital or Hitler's Mein Kampf. Mrs. Jennifer J. Johnson December 8, 1998
The international banking and law enforcement communities clearly desire that everyone's finances be readily available for inspection and visible for everyone to see. If this is such a good idea, I suggest that the 'Know Your Customer' program be tested first on a smaller scale to see if it will really work. Just last week, the media reported that Citibank engaged in a very large money laundering transaction with parties in Mexico. Since money laundering always involves some bank or other financial institution, supervisory federal agencies such as the Board should require that every financial institution post on the Internet the details of all their daily financial transactions. With such availability, millions of ordinary Americans can watch the operations of these institutions and billions of eyes are far better than a vastly smaller number of federal agents attempting to ferret out crime. Clearly, doing this would 'make a dent in crime.'
In addition to posting such banking information on the Internet, supervisory agencies such as the Board should also require all public officials and employees, state and federal, to weekly post on the Internet all of their financial information. You must admit that public officials have been convicted of crimes and some even facilitate drug running and money laundering with their banker friends. You must also acknowledge that crooked DEA, FBI, and Customs agents provide assistance to drug runners. Putting the banking and other financial records of these types on the Internet would allow millions of ordinary Americans to become involved with law enforcement and their assistance might be so great that Congress could actually decrease the size of some of these agencies. Not only would allowing citizen participation in law enforcement assist federal agencies, the result just might reduce the budget deficit.
In summary, if the 'Know Your Customer' program is so fantastic, it should first be implemented in the most crime prone areas noted above. If implementation there is a success, then perhaps imposing it upon innocent, law abiding Americans might thereafter be required. However, there is the very distinct possibility that implementing the program where it would be most effective may very well eliminate crime, in which event it will not be necessary to subject the average citizen to it. Mrs. Jennifer J. Johnson December 8, 1998 Page 10
Because there is no statutory foundation for this 'Know Your Customer' program, I demand that the proposed rules be withdrawn. But if they are not withdrawn, I suggest making additions to the rules requiring observance by federal law enforcement of other federal privacy laws. Finally, I recommend that this program first be tested against more crime ridden groups such as bankers and public officials before it is imposed on the American people.
Lowell H. Becraft, Jr. -------------------------------------------------------------------------- POLITECH -- the moderated mailing list of politics and technology To subscribe: send a message to email@example.com with this text: subscribe politech More information is at http://www.well.com/~declan/politech/ -------------------------------------------------------------------------- # # #
-- Robert Mangus (firstname.lastname@example.org), December 31, 1998
Thank you Robert for this update!
-- Mitchell Barnes (email@example.com), December 31, 1998.
Lowell Becraft is a noted constitutional lawyer. One of his main areas of concentration is taxation issues. He has defended a lot of people on "failure to file" income tax charges. (Most of us are not subject to or liable for federal or state income taxes -- but most file anyway because of brainwashing or FEAR).
Otto Skinner has excellent information on his web site about the income tax. If you are considering not allowing withholding or not filing, whether because of Y2K or constitutional reasons, check out
-- Mr D. (firstname.lastname@example.org), January 01, 1999.
Thanks Robert Mangus! This very topic came up on Gary North's site today ;-).
A Lawyer Responds to the Know Your Customer Proposal
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-- Leska (email@example.com), January 05, 1999.