Wilmer Hale has issued a briefing concerning the new voluntary platform to facilitate information sharing between the government and industry on topics related to AML and other financial crime issues.  It argues that this programme represents a significant step forward on 2 related priority areas for FinCEN: information sharing and public-private partnerships.  It appears that the FinCEN Exchange will convene briefings every 6-to-8 weeks among FinCEN, law enforcement and financial institutions to exchange targeted information on priority illicit finance threats, such as specific money-laundering methods and typologies.  Participation in the programme is strictly voluntary and does not introduce any new regulatory requirements.  It is unclear which financial institutions will participate in the FinCEN Exchange, or how those institutions will be selected; it is possible that the programme will be invitation-only, at least in the near term.   The article also notes that there are at least 3 separate Bills to reform the Bank Secrecy Act are currently being considered in the US Congress that have the potential to revamp many aspects of the BSA and the AML regulatory regime, including in the areas of information sharing and public-private partnerships

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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