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Resources for Federal Financial Institutions Examination Council (FFIEC)Interagency Guidance on Sharing Suspicious Activity Reports with Head Offices and Controlling CompaniesThe Federal Reserve System The Financial Crimes Enforcement Network, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision (collectively, the “Federal Banking Agencies”) is issuing this guidance to confirm that under the Bank Secrecy Act and its implementing regulations (and parallel provisions issued by the Federal Banking Agencies): (1) a U.S. branch or agency of a foreign bank may disclose a Suspicious Activity Report to its head office outside the United States; and (2) a U.S. bank or savings association (“depository institution”) may disclose a Suspicious Activity Report to controlling companies[See Footnote 1] whether domestic or foreign. This guidance does not address the applicability of any other Federal or state laws.
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