defensive " sars in an effort to avoid any criticism of their judgment about whether some activity is illegal or suspicious, and to avoid sanctions for failing to file particular sars. the treasury department's financial crimes enforcement network ( fincen ) has reported that these defensive filings threaten to clutter the sar database with information that cannot be properly analyzed due to the volume. bank regulators and fincen recognize that no process for fraud or money laundering detection and control can reasonably be expected to perfectly detect every transaction. but, financial institutions are expected to have a sound anti - money - laundering compliance program. this must include well - defined processes to identify suspicious activities, and those processes should be tailored to the risk and complexity of each business line. banks should provide sufficient training to line staff, compliance officers, internal auditors, and legal staff to keep employees on the alert for suspicious activities. further, when questionable activity is detected, the bank must respond promptly and effectively, and work with appropriate law enforcement authorities and bank regulators. i am sure that you are aware by now of the interagency efforts to develop and issue new, enhanced bank secrecy act examination guidelines and procedures within the next few months. the federal reserve and the other federal banking supervisors, with the active participation of fincen, are drafting these more - detailed uniform examination guidelines and procedures. we are reaching out to the industry during this stage of the project. once the procedures are completed, we will work hard to educate our examination forces and the industry about the guidelines and procedures. these efforts are intended to better ensure consistency in the bank secrecy act and anti - money - laundering supervision programs of the bank regulators and fincen - the entity within the u. s. treasury that is statutorily responsible for the implementing the bank secrecy act. in addition, the federal reserve and the other federal bank supervisory agencies recently signed a memorandum of understanding with fincen to share critical information about banking organizations'compliance with the bank secrecy act. by providing pertinent bank secrecy act information to fincen, which is adding additional staff to fulfill its responsibilities, the federal reserve and the other regulators can now better coordinate their supervision and enforcement efforts, thus further reducing the potential for unwarranted compliance burdens. fincen is also committed to providing both bankers and regulators information about emerging money - laundering schemes and guidance for continually improving bank secrecy act compliance. the federal reserve is also working with senior justice and treasury officials to ensure they understand the efforts of banks and the regulators

were spent in the service of africa. victor bruce ’ s illustrious career was launched not from a platform of privilege and wealth but from humble beginnings in tobago. following his early education at bishop ’ s high school, victor bruce joined the civil service and continued his education the hard way through evening classes, before going on study leave to the london school of economics. on his return to trinidad and tobago, he worked at the central statistical office before being appointed director of personnel administration and permanent secretary, ministry of tobago affairs in 1963. it was soon after, tobago had been devastated by hurricane flora and bruce ’ s assignment was to oversee the rehabilitation of the island ’ s damaged economy. bruce ’ s success at this assignment earned him his next appointment as deputy governor of the central bank of trinidad and tobago, on january 01, 1966. this was a little more than a year after the central bank was established in 1964 and it was a time when the post of governor was reserved for an expatriate, under technical assistance provided by the imf. bis central bankers ’ speeches in 1969, victor bruce broke this mould when he was appointed the first local central bank governor. in his fifteen years at the helm, victor bruce proceeded to establish the bank as arguably the most efficient public sector institution in trinidad and tobago. under bruce, the bank became an important player in the economic life of our nation as well as an active and respected participant in regional and international economic fora. victor bruce remains the longest serving governor of the central bank of trinidad and tobago. he was the dean of the central bank governors of the caribbean and latin america and, for years, was the region ’ s spokesman in the main international monetary organizations – the g - 20 and g - 77. as the first local central bank governor, victor bruce played a critical role in : • steering the banking system through localisation, and the political turmoil of the 1970s ; • managing the break with the pound sterling and the shift of the country ’ s peg to the us dollar ; • widening the network of commercial bank branches to allow easier access to banking services ; and • the creation of a number of capital market institutions, most notably, the trinidad and tobago stock exchange, the unit trust corporation and the home mortgage bank. the key to victor bruce ’ s phenomenal success was his uncompromising commitment to excellence. he demanded the highest standard of performance. shoddy work was unacceptable, as was shoddy conduct. bruce believed that central banks were,