Supervision and Regulation Letters

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SR 18-8:

Interagency Statement on Sharing Bank Secrecy Act Resources

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551

DIVISION OF
SUPERVISION AND REGULATION

SR 18-8
October 3, 2018

TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK

SUBJECT:

Interagency Statement on Sharing Bank Secrecy Act Resources

Applicability:  This guidance applies to all financial institutions supervised by the Federal Reserve that are subject to the Bank Secrecy Act.

The Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the U.S. Department of Treasury's Financial Crimes Enforcement Network are issuing the attached interagency statement to address instances in which banks1 may decide to enter into collaborative arrangements to share resources to manage their Bank Secrecy Act/Anti-Money Laundering (BSA/AML) obligations more efficiently and effectively.  Collaborative arrangements as described in this statement generally are most suitable for banks with a community focus, less complex operations, and lower-risk profiles for money laundering or terrorist financing.

The interagency statement does not alter existing BSA/AML legal or regulatory requirements, nor does it establish a supervisory expectation that banks engage in such collaborative arrangements. The establishment of collaborative arrangements should be approached like other business decisions, with due diligence and thorough consideration of the risks and benefits. Banks are encouraged to contact their primary federal regulator regarding sharing BSA resources, and should refer to other relevant guidance.

Federal Reserve Banks are asked to distribute this letter to the supervised institutions in their districts and to appropriate supervisory staff. Questions regarding this letter should be directed to the following individuals:

  • Division of Supervision and Regulation:  Koko Ives, Manager, BSA/AML Compliance Section, at (202) 973-6163 or Anthony DeVita, Senior Supervisory Financial Analyst, at (202) 728-5818; or
  • Legal Division:  Jason Gonzalez, Senior Special Council, at (202) 452-3275.

In addition, supervised organizations may send questions via the Board's public website.2

signed by
Michael S. Gibson
Director
Division of
Supervision and Regulation

Attachments:
Notes:
  1. Under the BSA, the term "bank" is defined in 31 CFR 1010.100(d) and includes each agent, agency, branch or office within the United States of commercial banks, savings and loan associations, credit unions, and foreign banks. Return to text
  2. See, http://www.federalreserve.gov/apps/contactus/feedback.aspx  Return to text
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Last Update: October 03, 2018