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Federal Banking Agencies Issue Interagency Statement on Sharing Bank Secrecy Act Resources

On October 3, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration and the Office of the Comptroller of the Currency released a joint statement related to the permissible sharing of Bank Secrecy Act (BSA) resources.

The joint statement supports the use of collaborative arrangements to achieve compliance with BSA requirements, where such arrangements comply with applicable law. The intent of the joint statement is to help banks reduce costs and obtain greater specialized expertise in connection with money laundering-related regulatory requirements. The joint statement identifies internal controls, independent testing and money laundering detection training as three areas in which such collaborative efforts may yield savings or other positive results for banks.

The joint statement reaffirms that banks are required to have a BSA and anti-money laundering compliance program that ensures compliance with BSA requirements and is commensurate with its respective risk profile.

The joint statement is available here

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About this Author

Christina J. Grigorian, Banking legal Specialist, Katten Muchin Law firm
Special Counsel

Christina J. Grigorian counsels clients in all matters related to banks, bank holding companies, and state and foreign-licensed consumer and commercial lenders. Ms. Grigorian provides advice to the firm’s financial institution clients concerning structural and operational issues, including legislative developments impacting such operations, and has worked with companies and individuals in the establishment of de novo entities, including national banks, federal savings banks and state-chartered institutions, as well as state-licensed lenders. She has also counseled clients with respect to...