services ; and key third party contracts. • finally, firms should have inventories of key legal information, including legal entity types, purpose and relevant licenses, physical location, regulator, senior management and directors ; and applicable resolution regime and authority, as well as sufficient information on legal agreements, such as parties to the agreements, key terms of agreements, and any relevant interdependencies. arrangements for shared or outsourced services • the final area for additional work is ensuring robust arrangements for the continued provision of shared or outsourced services needed to maintain operations. • firms should understand and have sufficient information available on its internal and external dependencies, including continuity or replacement strategies for each service, as well as contingency arrangements in place to retrain or replace personnel or services needed to maintain operations. • while there are many areas that supervisors / regulators and legislators need to continue to work on to make cross - border resolution a reality, these five areas are ones that we have highlighted for near - term focus by firms. • and just a note for firms in the next tiers, including the wave two and three filers – as i know that concerns have been raised about the depth and breadth of work required – particularly for the “ non - systemically important ” foreign banking organizations ( fbos ) : bis central bankers ’ speeches – 2. as we ’ ve indicated in our discussions, our reviews of your plans, which we are conducting jointly with the fdic, will be a learning experience for us – as much as it is for you. we are viewing this process as iterative – as it has been for the first wave filers, and we expect to learn quite a bit through the reviews, including much more about your u. s. operations, that will help us and you ensure a robust planning process that works for each firm. challenges of coordination turning now to the second area where i think more work needs to be done – coordinating the supervision and oversight of the large systemically important institutions. while the crisis has provided a great opportunity to enhance our dialogue across supervisory boundaries, there are still impediments to realizing a more seamless and coordinated approach. among the impediments are the challenges in information sharing, where there continue to be barriers to freely sharing information among supervisors. while some of these impediments are cultural – or trust - related – ones, there are still legal barriers to sharing information that need to be addressed. we need to address the legal

##bol ” clubs, or media companies with broadcasting rights to futbol events. although these payments did not steal government funds, they did impact nonprofit schools and futbol clubs that were supposed to be the recipient of much of these funds. multiple officials from clubs around the globe were prosecuted in the u. s. for those violations. one common theme in cases like these is that they tend to occur in countries where the powerful can easily take advantage of limited or immature internal controls. as is typical with most classic fraud triangle schemes, these people had the motivation ( greed or perceived financial pressure ), opportunity ( powerful positions with weak internal controls ), and rationalization ( they deserved the kickback for years of hard work ). and undoubtedly, they thought the chances of getting caught were slim. however, when the scheme to inflate contracts and pay the associated bribes are made in u. s. dollars, the settlement of those transactions will usually be routed through the united states. this means that u. s. prosecutors will be able to take action against those involved – even if their local governments will not or cannot pursue criminal or civil cases in their home country. many of the schemes i just mentioned were identified by banks around the globe and reported to authorities via suspicious activity reports ( sars ). those banks helped root out international corruption schemes. the united states has robust anti - money laundering laws that date back to 1970. but every so often the u. s. makes major changes to its laws and regulations in response to a significant event or risks. the most prominent was the patriot act after the 9 - 11 attacks in 2001. one year ago, the u. s. passed another significant piece of legislation – the anti - money laundering act of 2020, which has strengthened the position of the u. s. government to act against many financial crimes. some of the measures include : 2 / 3 bis central bankers'speeches the unmasking of the true owners and controlling members of shell companies in the united states will establish transparency that is so vitally needed in our financial system. the increased obligations of foreign respondent banks that maintain accounts in the u. s. to comply with requests for information from u. s. agencies and commensurate penalties for ignoring those requests. the potential for banks in the u. s. to share sars data with certain affiliates around the globe in order to better identify malfeasance. the clear statements of support for the use of new technologies to