The American Bankers Association today told the Financial Crimes Enforcement Network that the proposed pilot program for domestic financial institutions to share suspicious activity reports with their foreign branches, subsidiaries and affiliates “needs to be significantly revised” in order to be efficient and effective.
ABA has long supported the sharing of SARs with affiliates but acknowledged that the current approach of stripping out the SAR indicators before sharing only underlying information with affiliates creates many inefficiencies, “that unnecessarily consume resources that should be deployed to combat money laundering and terrorist financing . . . [P]ermitting SARs sharing with affiliates would facilitate the reallocation of resources currently devoted to a compliance exercise to efforts to combat illicit finance,” the association said.
To encourage participation in the proposed pilot program, ABA said that it should be streamlined and simplified, and that FinCEN should define how it will evaluate the success or failure of the program. The association also recommended that the pilot program be extended beyond the proposed January 2024 deadline in order to collect enough data to determine whether any changes would be needed to make the program permanent.
The association also recommended that FinCEN consider data that reflects whether participants have been able to share SAR data without inappropriate disclosures or violations of data security or confidentiality of those who are the subjects of the SARs being shared.