On October 3, 2018, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”), issued an interagency statement on sharing BSA resources (the “Interagency Statement”). The four-page Interagency Statement is a result of a working group recently formed by the Agencies aimed at improving the effectiveness and efficiency of the BSA/AML regime.

The Agencies recognize that banks use so-called “collaborative arrangements” to reduce costs, increase operational efficiencies, and leverage specialized expertise. The Interagency Statement addresses issues where banks decide to enter into such collaborative arrangements to manage their BSA and AML obligations more efficiently and effectively. However, the Agencies point out that such BSA/AML collaborative arrangements are most suitable for banks with a community focus, less complex operations, and a lower BSA/AML risk profile. In addition, the Agencies emphasize that the Interagency Statement does not alter a bank’s existing legal and regulatory requirements. Each bank ultimately remains responsible for its BSA/AML compliance based on its bank-specific risk profile, even if resources to manage BSA/AML risks are shared.