Introductory BSA/AML Examiner School, Atlanta, CA

INFORMATION SHARING

§1010.540 Voluntary information sharing among financial institutions

• Voluntary-includes associations and trade groups • Must file a Treasury certification • Only on suspected terrorist or money laundering activities • Must protect security & confidentiality • Must file a SAR, if appropriate • Safe Harbor

INFORMATION SHARING

Section 314(b) – Examination Procedures • Verify that notification to share information is filed with FinCEN.

• Determine the adequacy of policies and procedures. – Designate a point of contact to receive and furnish information. – Ensure safeguarding and confidentiality of information received and/or requested. – Establish a process for sending and responding to requests, including ensuring that the other parties have filed proper notice with FinCEN. – Contain procedures for determine when a SAR is appropriate.

• Review documentation of information shared and received. Determine if appropriate SARs were filed.