Isn there a conflict between sharing information for AML purposes and the financial privacy requirements of Reg S-P?
A. Good question. There is a safe harbor provision in the AML regulations. You must file an annual Information Sharing Notice with FinCEN and you must take reasonable steps to assure that the firm you share information with has also filed with FinCEN. Do a search on 31 C.F.R. 103.110(b) to get the exact wording of the safe harbor provision.
Related Questions
- Is there ever a situation where a commercial policy might cause a company to become subject to the requirements of the financial privacy regulation?
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