Compliance Blog

Jun 10, 2008
Categories: BSA

314(a) Fact Sheet Updated

FinCEN recently published an updated 314(a) fact sheet.  You can access it here.  The fact sheet gives a little background about the filing process and how feedback from institutions is used.  Here's a refresher:

FinCEN receives requests from federal law enforcement and upon review, sends requests to designated contacts within financial institutions across the country once every 2 weeks via either a secure Internet web site or via facsimile. The requests contain subject and business names, addresses, and as much identifying data as possible to assist the financial industry in searching their records. The financial institutions must query their records for data matches, including accounts maintained by the named subject during the preceding 12 months and transactions conducted within the last 6 months. Financial institutions have 2 weeks from the transmission date of the request to respond to 314(a) requests. If the search does not uncover any matching of accounts or transactions, the financial institution is instructed not to reply to the 314(a) request.

I hear from many credit unions that they've never had a "hit." That may lead some to think that the process might be a waste of time.  Not so fast, my friend.  Here's an interesting piece of information from the current fact sheet:

Based on the total feedback we have received using the current revised feedback reporting form, 55% of 314(a) requests have contributed to arrests or indictments

Wow. That number caught my eye.  For more information on the 314(a) process, you can visit FinCEN's 314(a) page here.