September 2012
PREPARED REMARKS OF PETER ALVARADO DEPUTY DIRECTOR FINANCIAL CRIMES ENFORCEMENT NETWORK
Today I would like to discuss the purpose and conduct of FinCEN's enforcement program, and how we work with the Federal banking agencies (FBAs) to conduct joint and concurrent enforcement actions, when possible, which in turn ensures a more consistent and uniform approach to Bank Secrecy Act (BSA) enforcement.
Administrative Ruling Regarding the Participation of Associations of Financial Institutions in the 314(b) Program (Rescinded by FIN-2020-R002)
Dear []:
This letter responds to your [] request to the Financial Crimes Enforcement Network ("FinCEN") for an administrative ruling on the definition of "association of financial institutions." Specifically, you requested a determination of whether [the Company] would be considered an association of financial institutions and allowed to participate in the voluntary information sharing program implemented under section 314(b) of the USA PATRIOT Act.1