The Clearing House Association L.L.C. (“The Clearing House”) responded to a request of the Financial Action Task Force (“FATF”) for information related to its development of implementation guidance for revised FATF Recommendation 16 and analysis of public-private AML/CFT information-sharing partnerships. The letter emphasizes the importance of legal frameworks that enable effective AML/CFT information sharing among financial institutions while integrating data protection and privacy safeguards by design, drawing on the U.S. experience under section 314(b) of the USA PATRIOT Act as a model. The letter offers recommendations with respect to cross-border information sharing challenges and encourages jurisdictions to provide institutions with flexibility to implement new AML/CFT information sharing technologies in a timely manner. The letter also notes The Clearing House’s support for voluntary public-private partnerships, such as those facilitated by FinCEN, and offers recommendations to jurisdictions on how to facilitate participation in such arrangements. To read the full letter click here.