Treasury’s FinCEN Allows Associations of Financial Institutions to Participate In Sharing of Anti-Money Laundering Information

On July 25, 2012, the Financial Crimes Enforcement Network (“FinCEN”) issued a ruling on the definition of “association of financial institutions.” It affirmed that an “early warning organization”, that is a limited liability company and is wholly owned by financial institutions, is able to share with other financial institutions the data it receives under § 314(b) of the USA Patriot Act.¹