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Key partner
Key Partners

The Financial Crimes Enforcement Network works closely with regulatory, law enforcement, private sector, and international partners. Among the entities with which we work especially closely are the Federal supervisory agencies, the Bank Secrecy Act Advisory Group, and the Egmont Group, all described below.

Federal Regulatory Agencies
Responsibility for conducting Bank Secrecy Act compliance examinations has been delegated to the following Federal agencies:

Federal Deposit Insurance Corporation

Board of Governors of the Federal Reserve System

Office of the Comptroller of the Currency (U.S. Department of the Treasury)

Internal Revenue Service, Small Business/Self-Employed Division (U.S. Department of the Treasury)

Office of Thrift Supervision (U.S. Department of the Treasury)

National Credit Union Administration

Securities and Exchange Commission

Commodity Futures Trading Commission
The Financial Crimes Enforcement Network provides assistance and support to these agencies to promote effective and uniform application of the Bank Secrecy Act regulations.

Bank Secrecy Act Advisory Group
Congress established the Bank Secrecy Act Advisory Group in 1992 to enable the financial services industry and law enforcement to advise the Secretary of the Treasury on ways to enhance the utility of Bank Secrecy Act records and reports. Since 1994, the Advisory Group has served as a forum for industry, regulators, and law enforcement to communicate about how Suspicious Activity Reports and other Bank Secrecy Act reports are used by law enforcement and how record keeping and reporting requirements can be improved. The Director of the Financial Crimes Enforcement Network chairs the Bank Secrecy Act Advisory Group.

The Bank Secrecy Act Advisory Group, which is not subject to the Federal Advisory Committee Act, meets twice each year in Washington, DC. In light of the expansion of Bank Secrecy Act requirements since the enactment of the USA PATRIOT Act of 2001, the Financial Crimes Enforcement Network has been taking steps to ensure that the Bank Secrecy Act Advisory Group continues to fully and fairly reflect the entire Bank Secrecy Act constituency. The Advisory Group now has 50 members.

The Bank Secrecy Act Advisory Group utilizes a variety of permanent and ad hoc subcommittees to identify and analyze relevant issues. Current subcommittees focus on: Suspicious Activity Report issues; Bank Secrecy Act examination consistency; wire transfer reporting thresholds; privacy/security issues; non-bank financial institutions issues; securities/futures issues; law enforcement issues; and reducing the filing of Currency Transaction Reports with little or no value to law enforcement. The Bank Secrecy Act Advisory Group also co-chairs publication of The SAR Activity Review—Trends, Tips & Issues, which provides meaningful information to the financial community about the preparation, use, and value of Suspicious Activity Reports.

Need for Government-Private Sector Partnership
"I am convinced that if we are ever going to achieve our goal of truly safeguarding the financial system from criminal abuse under the current paradigm, the government and private sector must act in true partnership. The word 'partnership' gets thrown around an awful lot these days, at least in the United States, and this tends to breed a great deal of cynicism. Partnership demands a commitment on both sides. For the private sector this means a commitment to develop and implement reasonable, risk-based programs to address the risks of financial crime posed by each private sector member's business lines and customer base. This program should result in the reporting of suspicious activity and other relevant information to the government when appropriate. The government, in turn, must educate the private sector about the risk and "most importantly "be willing to share information with the private sector so they can develop their programs to address the risks associated with their business and customers...

"The 20th Century paradigm of governments alone protecting their citizens from outside threats is no longer valid in a post-September 11 world. This paradigm simply no longer applies when enemies can melt into society and commandeer aircraft to use as missiles of devastation, or when a group of mad men board public transportation and murder innocent souls who are simply trying to live and work in the world. Good partners talk with one another. I am convinced that if we are to make the present regime work, government and the private sector need to be in a constant dialogue on these issues."

--William J. Fox, Cambridge International Symposium on Economic Crime, September 5, 2005

The Egmont Group
The Egmont Group is a global association of 101 financial intelligence units, national centers that have been set up to collect information on suspicious or unusual financial activity from the financial industry, to analyze the data, and to make it available to appropriate national authorities and other financial intelligence units for use in combating terrorist funding and other financial crime. The Group takes its name from the palace in Brussels where 15 financial intelligence units first met in 1995 to establish an informal group for sharing information about money laundering.

The Financial Crimes Enforcement Network has played a major role in helping other countries develop their financial intelligence units, and we help those units strengthen anti-terrorist financing and money laundering policies and programs. We also sponsor new financial intelligence units for membership in the group and provide a secure web system through which Egmont members can exchange information. Our Deputy Director chairs the Egmont Committee, which coordinates Egmont Group activities. We also provide staff support for Egmont's five working groups, which are described below:

The Legal Working Group reviews the candidacy of potential members and handles all legal aspects and matters of principle within Egmont, including cooperation between financial intelligence units.

The Outreach Working Group seeks to create a global network of financial intelligence units by identifying candidates for membership and working with them to ensure that they meet international standards.

The Training Working Group identifies training opportunities for financial intelligence unit personnel. The Training Working Group has also published a collection of sanitized terrorist and money laundering cases that were used at the typology exercises of the Financial Action Task Force, an inter-governmental body that develops and promotes national and international policies to combat money laundering and terrorist financing.

The Operational Working Group seeks to bring financial intelligence units together on cases and strategic projects such as insurance schemes and stored value.

The IT (Information Technology) Group examines new software applications that might facilitate analytical work and focuses on such issues as data mining, information fusion, and security.
Egmont Group Achievements
"A review of what has happened over the past decade can lead to only one conclusion . . . that the Egmont Group has achieved [its] original goals in spectacular fashion. Right now that original handful of units has expanded to 101 countries and jurisdictions each of which has made a commitment to put the resources in place to accomplish what the FATF envisioned. The fact that 101 countries and jurisdictions have established units is impressive in its own right, but what is even more important is that each FIU has made a commitment to share the information they collect with other FIUs. We all know it works. We see it in action every day."

--William J. Fox, 13th Plenary Session of Egmont Group, June 30, 2005