File #: RS2024-693   
Type: Resolution Status: Passed
File created: 8/22/2024 In control: Metropolitan Council
On agenda: 9/3/2024 Final action: 9/3/2024
Title: A resolution approving an intergovernmental agreement between the Metropolitan Nashville Police Department ("MNPD") and the Financial Crimes Enforcement Network ("FinCEN"), a bureau within the U.S. Department of the Treasury, for direct electronic access to financial information collected pursuant to the reporting authority of the Bank Secrecy Act ("BSA").
Sponsors: Delishia Porterfield, Erin Evans, Jordan Huffman
Attachments: 1. Memorandum of Understanding

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A resolution approving an intergovernmental agreement between the Metropolitan Nashville Police Department (“MNPD”) and the Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Department of the Treasury, for direct electronic access to financial information collected pursuant to the reporting authority of the Bank Secrecy Act (“BSA”).

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WHEREAS, MNPD has entered into an agreement with FinCEN to obtain access to financial information protected by the BSA and collected by FinCEN, to aid MNPD with the identifications, investigations, or prosecutions of possible violations of law that fall within the jurisdiction of MNPD;

WHEREAS, MNPD agrees to the sharing and safeguard protocols outlined by FinCEN in

the Re-Dissemination and the Information Access Security Protocols for Bank Secrecy Information attached hereto; and,

WHEREAS, it is in the interest of the citizens of The Metropolitan Government of Nashville and Davidson County that this intergovernmental agreement be approved.

NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE METROPOLITAN GOVERNMENT OF NASHVILLE AND DAVIDSON COUNTY:

Section 1.  That the intergovernmental agreement between the Metropolitan Nashville Police Department (“MNPD”) and the Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Department of the Treasury, a copy of which is attached hereto and incorporated herein, is hereby approved, and the Metropolitan Mayor is authorized to execute the same.

Section 2.  That this resolution shall take effect from and after its adoption, the welfare of The Metropolitan Government of Nashville and Davidson County requiring it.

Agenda Analysis

Analysis

 

This resolution approves an intergovernmental agreement between the Metropolitan Nashville Police Department (“MNPD”) and the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, for direct electronic access to financial information collected through the reporting authority of the federal Bank Secrecy Act.

 

MNPD entered into the agreement to continue accessing financial information protected by the Bank Secrecy Act and collected by FinCEN. The information would assist MNPD with identifications, investigations, and prosecutions of criminal offenses in Nashville and Davidson County. MNPD would agree to various re-dissemination and information access security protocols as part of the agreement.

 

The MOU becomes effective on the first month following the date which it is signed on FinCEN’s behalf and continues for five years. The agreement may be renewed for additional five-year terms upon mutual written agreement.

 

Fiscal Note: There is no cost to Metro to access the BSA (Bank Secrecy Act) information or travel expenses of FinCEN personnel for the purposes of exercising FinCEN’s inspection rights or providing training.