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"), 1 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.2 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
