OCC 2006-4
OCC Bulletin

    Subject:  Bank Secrecy Act/Anti-Money Laundering
Description:  Joint Statement on Sharing Suspicious Activity 
              Reports with Controlling Companies

       Date:  January 27, 2006

TO:  Chief Executive Officers of All National Banks,
     Department and Division Heads, and All Examining Personnel

The attached document, issued on January 20, 2006, provides a
statement from the Office of the Comptroller of the Currency
(OCC), the Board of Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation, the Office of Thrift
Supervision, and the Financial Crimes Enforcement Network to
banking organizations regarding the Bank Secrecy Act and the
sharing of Suspicious Activity Reports (SAR) with controlling
companies.

The federal banking agencies have determined that a U.S. branch
or agency of a foreign bank may share a SAR with its head office
outside the United States for the purpose of identifying and
reporting suspicious activity.  Similarly, a bank or savings
association may disclose a SAR to its controlling company, no
matter where the entity or party is located.  In the event that a
depository institution's corporate structure includes multiple
controlling companies, the filing institution's SAR may be shared
with each entity that has a controlling interest.

For further information, please contact your examiner-in-charge,
OCC supervisory office, or the OCC Compliance Policy Department
at (202) 874-4428.


Ann F. Jaedicke
Deputy Comptroller for Compliance Policy


Attachment:  Joint Interagency Statement
          [http://www.fincen.gov/sarsharingguidance01122006.pdf]