In an interagency statement, the Federal Reserve Board, FDIC, National Credit Union Administration, Office of the Comptroller of the Currency and FinCEN (collectively, the "agencies") addressed instances in which banks may share resources collaboratively in order to manage their Bank Secrecy Act ("BSA") and anti-money laundering ("AML") obligations.

The agencies stated that collaborative arrangements are most suitable for community banks, which maintain "less complex operations and lower risk profiles for money laundering and terrorist financing." The interagency statement made clear that "the use of collaborative arrangements to manage BSA/AML obligations requires careful consideration regarding the type of collaboration in relation to the bank's risk profile, adequate documentation, consideration of legal restrictions, and the establishment of appropriate oversight mechanisms; and should be consistent with sound principles of corporate governance." The agencies provided examples of several types of collaborations in which banks could share resources and technologies.

The interagency statement does not apply to collaborative arrangements formed for the purpose of sharing information under Section 314(b) of the USA PATRIOT Act.

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