Compliance Blog

Jun 09, 2009
Categories: BSA

314(a) Requests

Every so often, FinCEN issues a 314(a) fact sheet update.  Here's the most recent edition, which FinCEN issued yesterday.

In case you thought the process was a huge waste of time, it has nailed some bad dudes.

To date, the 314(a) Program Office has processed 979 requests submitted by twenty-two Federal agencies. Federal law enforcement organizations have submitted cases in the conduct of the following significant criminal investigations:

Terrorism/Terrorist Financing – 302 cases

Money Laundering – 677 cases

These requests included 9,105 subjects of interest. Of these, financial institutions have responded with 61,817 total subject matches: 60,779 positive and 1,038 inconclusive.

If you have questions on how to complete 313(a) requests, this chapter of the BSA manual does a good job of providing a basic overview.  But I've been told that the best instructions actually are included with the 314(a) transmittal sheet itself.  So, the next time you process the request, keep the instructions portion of the 314(a) transmittal sheet.  It might come in handy if you need to address 314(a) issues on the fly.