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3/19/2020

Federal Agencies Issue a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Ba…

Federal Agencies Issue a Joint Statement on Banks and Credit
Unions Sharing Resources to Improve Efficiency and
Effectiveness of Bank Secrecy Act Compliance
October 3, 2018

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 antimoney laundering (AML) obligations more e iciently and e ectively. 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 O ice 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 O ice of Terrorism and Financial Intelligence
aimed at improving the e ectiveness and e iciency of the BSA/AML regime.
“This joint statement is part of a broader e ort 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
sta , technology, or other resources, to increase operational e iciencies, reduce costs, and
leverage specialized expertise; and
https://home.treasury.gov/news/press-releases/sm502

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3/19/2020

Federal Agencies Issue a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Ba…

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 e iciently and e ectively. 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.
Joint Interagency Statement on Sharing Bank Secrecy Act Resources
####

Agency

Contact

Phone

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

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