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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.)
Correct Answer: A,B
Banks must adhere to strict privacy laws and SAR confidentiality rules when handling customer information, especially in cross-border investigations. Option A (Correct): Banks must consider privacy laws such as the US Bank Secrecy Act (BSA), the EU General Data Protection Regulation (GDPR), and their internal policies before sharing data. Option B (Correct): Information should be shared only on a need-to-know basis, ensuring compliance with AML regulations and internal procedures. Option C (Incorrect): While FinCEN provides SAR guidance, banks do not need to seek FinCEN's permission for every internal information request. Option D (Incorrect): International requests must comply with legal frameworks, but there is no universal requirement for approval by national authorities.