Agencies Issue Joint Statement on Resource-Sharing for BSA Compliance

On October 3, 2018 the three banking agencies, jointly with the National Credit Union Administration and the Financial Crimes Enforcement Network, 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 BSA/AML obligations more efficiently and effectively. The agencies note that collaborative arrangements are generally most suitable for financial institutions with a community focus, less complex operations, and lower risk profiles for money laundering or terrorist financing. The statement explains how these institutions can share BSA/AML resources in order to better protect against illicit finance risks, which can in turn reduce costs.

The joint statement:

  • Highlights the potential benefits of collaborative arrangements that pool resources, such as staff, technology, or other resources

  • Outlines risk considerations and mitigation measures associated with the use of collaborative arrangements.

While acknowledging the benefits of using shared resources to manage certain BSA/AML obligations more efficiently, the joint statement notes that financial institutions should approach the establishment of collaborative arrangements like other business decisions, applying appropriate due diligence and a thorough consideration of the risks and benefits.

The complete joint statement can be found here. 

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