Agencies issue joint statement on sharing AML/BSA resources

Oct. 4, 2018 -- Yesterday, the federal depository institutions regulators, including NCUA, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a statement noting instances in which banks and credit unions can share resources to manage their Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations more efficiently and effectively. The statement describes the collaborative arrangements as most suitable for financial institutions with a community focus, less complex operations, and lower-risk profiles for money laundering or terrorist financing. 

In addition to NCUA, the statement was issued by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, FinCEN, and the Office of the Comptroller of the Currency. It explains how these institutions can share BSA/AML resources to better protect against illicit finance risks, which can in turn also reduce costs. The 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.

Among other things, the 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. Institutions are encouraged to contact their primary federal regulator with questions regarding sharing BSA resources and should refer to other relevant guidance.

Interagency Statement on Sharing Bank Secrecy Act Resources