Board of Governors of the Federal Reserve System Federal
Deposit Insurance Corporation Financial Crimes Enforcement Network National Credit Union Administration Office of the Comptroller of the Currency
Federal Agencies Issue a Joint Statement
on Banks and Credit Unions Sharing Resources to Improve Efficiency and
Effectiveness of Bank Secrecy Act Compliance
WASHINGTON—The federal depository institutions regulators
and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network
(FinCEN) today issued a statement to address instances in which certain banks
and credit unions may decide to enter into collaborative arrangements to share
resources to manage their Bank Secrecy Act (BSA) and anti-money laundering
(AML) obligations more efficiently and effectively. Collaborative arrangements as described in
the statement generally are most suitable for financial institutions with a
community focus, less complex operations, and lower-risk profiles for money
laundering or terrorist financing. The
statement, which was issued by the Board of Governors of the Federal Reserve
System, the Federal Deposit Insurance Corporation, FinCEN, the National Credit
Union Administration, and the Office of the Comptroller of the Currency, explains
how these institutions can share BSA/AML resources in order to better protect
against illicit finance risks, which can in turn also reduce costs. Today’s joint statement is a result of a
working group recently formed by these agencies and Treasury’s Office of
Terrorism and Financial Intelligence aimed at improving
the effectiveness and efficiency of the BSA/AML regime.
“This joint statement is part of a broader effort to work
closely with our regulatory partners to strengthen the anti-money laundering
defenses across the U.S. financial system,” said Sigal Mandelker, Treasury
Under Secretary for Terrorism and Financial Intelligence. “The joint
statement allows community-focused banks and credit unions to share certain anti-money
laundering resources in order to better protect against illicit actors seeking
to abuse those types of institutions. Such
resource sharing must be approached with careful due diligence and thorough
consideration of the risks and benefits.”
Among other things, today’s joint statement aims to:
- Highlight the potential benefits of collaborative arrangements that pool resources, such as staff, technology, or other resources, to increase operational efficiencies, reduce costs, and leverage specialized expertise; and
- Outline risk considerations and mitigation measures associated with the use of collaborative arrangements.
The joint statement acknowledges
that banks and credit unions may benefit from using shared resources to manage
certain BSA/AML obligations more efficiently and effectively. However, it notes that financial institutions
should approach the establishment of collaborative arrangements like other
business decisions, with due diligence and thorough consideration of the risks
and benefits. Banks and credit unions
are encouraged to contact their primary federal regulator with questions
regarding sharing BSA resources, and should refer to other relevant guidance.
Federal Reserve Eric Kollig 202.452.2955 FinCEN Steve Hudak 703.905.5149 FDIC Julianne Fisher Breitbeil 202.898.6895 NCUA Ben Hardaway 703.518.6333 OCC William Grassano 202.649.6870
FDIC: PR-68-2018
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