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 risk considerations and corresponding mitigation and that sharing of a BSA officer among banks may be problematic.
The agencies noted that the statement did not apply to collaborative arrangements formed for sharing information pursuant to Section 314(b) of the USA PATRIOT Act, nor are banks participating in a collaborative arrangement an association for purposes of Section 314(b) of the USA PATRIOT Act.
The full text of the interagency statement is available at: https://www.occ.treas.gov/news-issuances/news-releases/2018/nr-ia-2018-107a.pdf.
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