Do you rely on a third party or your core processing vendor to conduct your 314(a) searches?
If yes, are you logging into FinCEN’s Secure Information Sharing System (SISS) and downloading each 314(a) list so the third party/core processor can run it against your customer records?
Find all your BSA Resources HERE!
If you rely on a third-party/core processor to download the 314(a) lists on your behalf, you likely have a problem. While you can rely on them to run the searches against your customer records, each individual bank MUST still have a 314(a) contact person, and each bank/contact MUST log into FinCEN’s SISS themselves in order to download the 314(a) lists.
The issue is not necessarily that banks could receive different 314(a) lists. FinCEN confirmed that the same list is generally provided to all banks. The only time a list “may” differ is IF there’s a targeted, special list that pertains to a specific area. That said, we are not aware of any such targeted lists.
This issue is that you cannot allow a third party to download the lists that it receives from FinCEN, on your behalf. EACH bank MUST log in and download their own 314(a) lists. We don’t see a lot of issues with this but It might be a good idea to verify that you have a contact person in your bank, that they are receiving the communications from FinCEN and THEY are logging in to download the 314(a) lists.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!