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Subject: Bank Secrecy Act/Anti-Money Laundering
Date: January 27, 2006
To: Chief Executive Officers of All National Banks, Department and Division Heads, and All Examining Personnel
Description: Joint Statement on Sharing Suspicious Activity Reports with Controlling Companies
The guidance attached to this bulletin continues to apply to federal savings associations.
The attached document, issued on January 20, 2006, provides a statement from the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the Financial Crimes Enforcement Network to banking organizations regarding the Bank Secrecy Act and the sharing of Suspicious Activity Reports (SAR) with controlling companies.
The federal banking agencies have determined that a U.S. branch or agency of a foreign bank may share a SAR with its head office outside the United States for the purpose of identifying and reporting suspicious activity. Similarly, a bank or savings association may disclose a SAR to its controlling company, no matter where the entity or party is located. In the event that a depository institution's corporate structure includes multiple controlling companies, the filing institution's SAR may be shared with each entity that has a controlling interest.
For further information, please contact your examiner-in-charge, OCC supervisory office, or the OCC Compliance Policy Department at (202) 874-4428.
Ann F. Jaedicke