FinCEN released an update to promote financial institutions utilizing sharing through Section 314(b) of the PATRIOT Act. The update contained a fact sheet that provides information on what Section 314(b) is and some of the benefits for completing the required form in order to share information with other financial institutions with respect to money laundering and terrorist financing.
Some of the benefits indicated by FinCEN include:
- Gathering additional and potentially invaluable information on customers or transactions potentially related to money laundering or terrorist financing, including previously unknown accounts, activities, and/or associated entities or individuals.
- Shedding more comprehensive light upon overall financial trails, especially if they are complex and appear to be layered amongst numerous financial institutions, entities, and jurisdictions.
- Building a more comprehensive and accurate picture of a customer’s activities where potential money laundering or terrorist financing is suspected, allowing for more precise decision-making in due diligence and transaction monitoring.
- Alerting the contacted financial institution to customers about whose suspicious activities it may not have been previously aware.
- Facilitating the filing of more comprehensive and complete SARs than would otherwise be filed in the absence of 314(b) information sharing.
- Aiding in identifying and collectively stemming money laundering and terrorist financing methods and schemes.
The fact sheet even describes how a credit union can participate in Section 314(b) sharing. However, keep in mind that this is voluntary, not require. FinCEN does encourage financial institutions to participate. That being said, I recommend that the credit union familiarize itself with the requirements and limitations of sharing this type of information first. I also recommend that if the credit union chooses to participate, it should update its policy and procedures with respect to its implementation.