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An international bank is headquartered in Madrid, Spain with an office in New York City...

An international bank is headquartered in Madrid, Spain with an office in New York City (NYC), US. The Madrid office is investigating a transaction originating from a customer of the NYC office and inquires whether the NYC office can share any relevant further information on the individual. Upon further research, the NYC office finds that they have filed a suspicious activity report (SAR) on the individual in the previous year.

Which factors need to be considered before sharing the requested information? (Select Two.)

A.

The foreign bank must always request approval by its national anti-financial crime authority to share any information cross-border.

B.

The bank should report this to the Financial Crimes Enforcement Network (FinCEN) and receive formal guidance before sharing the information.

C.

The bank should consider jurisdictional privacy requirements and its own policies and procedures to determine what information to share.

D.

The information should only be shared on a need-to-know basis.

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