bank secrecy act / anti- money laundering (bsa/aml) compliance

Information Sharing - 314(b) Requests• Between financial institutions• An FI must notify FinCEN of its intent to engage in informationsharing, and that it has established and will maintain adequateprocedures to protect the information• A notice to share information is effective for one year• Should ensure that the other FI or association has filed itsrequired FinCEN notice• Cannot share SARs or SAR filing information– If request relates to a transaction subject to a SAR,disclose only the transaction and member informationrequested