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FinCEN, the information sharing certificate, and program elements
Question: We are thinking about filing an information sharing certificate with FinCEN. Are there any program elements we should consider?
Answer: Yes - there sure are. First, be sure that you know how information will be shared. It's a good idea to have an information gatekeeper. You should know what information is shared and what information is obtained by your institution through this program. Having a gatekeeper enables you to track the flow of information and ensure compliance. Everyone in the institution should know about the process and that it must go through the gatekeeper. Most important, everyone should know who the gatekeeper is.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 7, 6/02
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