The financial regulatory agencies and the Financial Crimes Enforcement Network today issued a joint statement outlining how banks may enter into collaborative arrangements to share resources in order to more effectively manage their Bank Secrecy Act and anti-money laundering obligations. The agencies described several situations where collaboration might be beneficial for financial institutions, such as conducting internal control functions, independent testing and BSA/AML training.
When entering into collaborative arrangements, banks should carefully consider the arrangement in relation to the bank’s risk profile, ensure adequate documentation, consider legal restrictions, establish appropriate oversight mechanisms, and ensure that the arrangement is consistent with sound principles of corporate governance, the statement said. The agencies added that “ultimately, each bank is responsible for ensuring compliance with BSA requirements” and that “sharing resources in no way relieves a bank of this responsibility.”
