Davis Polk partner Dan Stipano was quoted in a MoneyLaundering.com article about certain large U.S. banks forming a private association to exchange financial intelligence. The association will investigate alleged financial crimes as well as networks whom are flagged by federal law enforcement through section 314(a) of the Patriot Act. Dan noted that the size of the banks involved and their ability to combine details of suspicious transactions makes the association noteworthy, but stated that, “as a legal matter it’s pretty unremarkable…[because] the rule from the beginning has allowed to share information under 314(b).”

Large US Banks Sharing Financial Intelligence Through Private Exchange, MoneyLaundering.com (October 8, 2021) (subscription required)