The new rules have resulted in changes in some record keeping practices and standards, while resulting in more spending on upgrading records management systems to enable banks and financial institutions to meet the requirements required by the Patriot Act.

Jewelry industry
Entities that engage in trade having to do with jewelry and precious metals have to keep records based on set criteria. The types of records to be kept were amended based on the Bank Secrecy Act.

Records Management and the Act generally
Many industries have had to revise their retention schedules on the heels of the Patriot Act so that they can find the information requested by authorized agencies if requested.

Most records managers know that any new legislation that has any impact, however, on the creation and control of records will necessitate a review and in some instances a revamping of current RIM (records and information management) policies. The Patriot Act was no different, and as stated above, in most, possibly all instances incurred additonal costs.

Section 215 of the Act allows the Director of the FBI to get some types of business records if these records are believed necessary to investigate terrorism. In the beginning, a court order was necessary, but this was changed so that a court order was no longer a requirement.

Interestingly, arising from the Patriot Act, the development of not only retention schedules, but destruction schedules for all categories of records including electronic records and email became top priority in many institutions.

In essence, a formal records management policies and procedures manual became necessary. Case in point, many universities had to form working groups and committees to revisit their records management policies and procedures. UC Berkeley, for example, had a number of groups reviewing the Patriot Act against existing policies. One such group was the Records Working Group whose mandate was to "review existing policies, procedures and standards governing the disclosure or records and make recommendations for any necessary changes..."

Electronic records
Another important impact on records management that is often overlooked is the resultant change in how electronic records, including emails, are viewed and kept. We've covered email archiving a lot in recent months, and the Patriot Act increases requirements for archiving and availability.

Impact on other countries
The impact of the Act on records management is far-reaching and affects countries other than the USA. Even a small country like my own Jamaica is impacted by the Patriot Act. The Act has resulted in stronger anti-money laundering acts in many countries, especially those that have trade relationships with the US.

Many foreign countries now have to implement measures so that they can provide the information on the identity of their customers, especially where the bank has corresponding relationship with a US bank. This has resulted in a "know your customer" caveat of sorts for banks worldwide. Foreign banks such as FirstCaribbean which operates in a number of Caribbean countries have to complete a Patriot Act Certification document