May 15, 2001
The Honorable Paul H. O'Neill
Secretary of the Treasury
1500 Pennsylvania Ave NW
Washington, DC 20220
Dear Secretary O'Neill,
The undersigned organizations, representing a diverse and broad cross-section of American society, are concerned that the Administration is not adequately safeguarding privacy in
the context of certain international initiatives in the area of investigations regarding financial crimes. Specifically, we are concerned that the proposals of the Organization for Economic Cooperation and
Development (OECD) and the Financial Action Task Force (FATF) for increased bank reporting on customers do not respect our financial privacy.
We recognize your increased concern for the tax implications with the OECD and the FATF but are concerned that you have not made privacy a sufficient priority. The current
proposals of OECD and FATF attempt to institute the popularly rejected "Know Your Customer" financial regulation, thereby sidestepping the domestic legislative process. We are concerned about the attempt
to get Know Your Customer adopted as an international "best practice" under the guise of increasing transparency.
Over 300,000 citizens filed comments against the Know Your Customer proposal under the Clinton Administration. We are disappointed that the Bush Administration continues to pursue
an approach that Larry Lindsey has described as ineffective: 99.999% of all Currency Transaction Reports filed are on law-abiding citizens going about their normal business. The Suspicious Activities Reports'
approach discriminates against the poor, as well as racial and ethnic minorities.
The OECD and FATF's campaigns against banking secrecy and "harmful tax competition" are problematic for several reasons. This approach undermines the public confidence
between individuals and their financial institutions, accountants and lawyers. These policies would likely distort capital inflows to the United States and could act, effectively, as capital controls. Economic
dislocations to affected countries could lead to unintended political, foreign policy and immigration concerns. Our modern economy requires a liberal capital policy that engenders the consumer trust that comes with
respect for privacy. We strongly urge you to make a clear statement instituting policies that respect financial privacy and that the Treasury Department opposes the type of reporting requirements being advanced by
the OECD and FATF.
Paul M. Weyrich
Coalitions for America
J. Bradley Jansen
Coalition for Constitutional Liberties
James J. Fotis
Law Enforcement Alliance of America
American Association of Physicians and Surgeons
National Taxpayers Union
Andrew F. Quinlan
Center for Freedom and Prosperity
Frances B. Smith
Founder and Editor
CASPIAN - Consumers Against Supermarket Privacy Invasion and Numbering
Gordon S. Jones
Association of Concerned Taxpayers
Henry A. Whitmore
People Against Church Taxation
The Liberty Committee
America's Survival, Inc.
Lisa S. Dean
Free Congress Foundation
Center for Democracy and Technology
George C. Landrith
Frontiers of Freedom
Council for Citizens Against Government Waste
Competitive Enterprise Institute
Edward A. Mallett
National Association of Criminal Defense Lawyers
Criminal Justice Policy Foundation
American Policy Center
Coalition for a Tax-Free Internet
The National Center for Public Policy Research
Richard W. Rahn
Republican Liberty Caucus
Jon C. Pastore
Young Americans for Freedom
Dr. Patricia McEwen
Life Coalition International
Director of Operations
Christian Coalition of California
Aaron Starr, CPA
Libertarian Party of California
Eagle Forum of Alabama
Concerned Women for America of Missouri
Julaine K. Appling
Family Research Institute of WI
Libertarian Party of Utah
Bobby L. Hester
American Family Association of Arkansas
Cedric and Sandi Boehr
Kansas Constitution Party
Montana Libertarian Party
James A. Landrith, Jr.
Editor & Publisher
The Multiracial Activist
and The Abolitionist Examiner
Global Strategic Management
AWS Construction Services, Inc.
The Whalen Consulting Group
David A. Hodgkinson
D.A. Hodgkinson, CPA.
Ely & Company, Inc.