US Federal Financial Regulatory Agencies Release Joint Statement On Sharing Bank Secrecy Act Resources

Author:Shearman & Sterling LLP
Profession:Shearman & Sterling LLP

On October 3, 2018, the U.S. Federal Reserve, FinCEN, OCC, FDIC and NCUA released an interagency statement regarding the sharing of Bank Secrecy Act resources among banks through collaborative arrangements intended to improve efficiency, reduce costs and benefit from specialized expertise by pooling resources among banks. The agencies stated that these types of collaborative arrangements may be more suitable for community banks with smaller footprints and less complex risk profiles. The agencies also provided examples of how these collaborative agreements may be effectively used in the BSA context, such as developing policies and procedures, processes and reports; providing for independent testing of BSA/AML programs; and leveraging pooled resources to provide BSA/AML training. The agencies also stated that special care and consideration should be taken with respect to collaborative arrangements to ensure proper evaluation of...

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