Compliance Blog

Dec 06, 2017
Categories: BSA

FinCEN Launches Information Sharing Exchange Program

The Financial Crimes Enforcement Network (FinCEN) wants to strengthen information sharing with financial institutions.  To help achieve this, it announced it has launched its FinCEN Exchange program to enhance public-private information sharing.  Working closely with law enforcement, FinCEN plans to convene regular briefings with financial institutions to exchange information on important potential illegal finance threats.   The program is intended to help financial institutions better identify risks and better focus on higher priority issues.  This will in turn help FinCEN and law enforcement get critical information to continue the fight against money laundering and other financial crimes.

Participation in the FinCEN Exchange is strictly voluntary with no new regulatory requirements.  It also doesn't replace or affect any existing channels by which law enforcement interacts directly with the financial industry. FinCEN indicates operational briefings under this new program will start in the coming weeks.

Historically, FinCEN has convened over a dozen special briefings in five cities with over 40 financial institutions and multiple law enforcement agencies since 2015.  According to FinCEN, the information given by financial institutions through suspicious activity reports (SARs) after these briefings has helped the public sector map out and target weapons proliferators, sophisticated global money laundering operations, human trafficking and smuggling rings, and corruption and trade-based money laundering networks.  The briefings also helped financial institutions to focus on specific priorities and better identify risks.

The FinCEN Exchange will convene more regularly scheduled and as-needed operational briefings across the nation with law enforcement, FinCEN and financial institutions to exchange information on priority illegal finance and national security threats.  In consultation with law enforcement, FinCEN plans to invite financial institutions to participate based on a variety of factors, including whether an institution may have information that is relevant to a particular topic. 

FinCEN states the form of each briefing may vary but the sharing of information is intended to equip financial institutions to provide more responsive information into SARs. Financial institutions are also highly encouraged, as appropriate, to voluntarily share information with other FinCEN Exchange participants as well as other financial institutions or associations of financial institutions pursuant to Section 314(b) of the USA PATRIOT Act.

About the Author

Shari Pogach, NCCO, NCBSO, Regulatory Paralegal, NAFCU

 Shari Pogach, NCCO, NCBSO, Regulatory Paralegal

Shari R. Pogach, NCCONCBSO, has served as Regulatory Paralegal for NAFCU's Regulatory Compliance and Regulatory Affairs divisions since 2007.

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