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#1613028 - 10/05/11 09:43 PM 314(a) Searches
Cedar Point Guy Offline
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Cedar Point Guy
Joined: Nov 2009
Posts: 732
Cedar Point
Hi All,

When conducting the 314(a) searches for documented evidence that the 314(a) search has been completed, will just the view of detail(might have this name incorrect) screen work for documented evidence? It is the screen from the 314(a) website that states the time, date, and what searched screen is what I am referring to.
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#1613117 - 10/06/11 01:18 PM Re: 314(a) Searches Cedar Point Guy
BC78a Offline
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BC78a
Joined: May 2006
Posts: 311
New York
Just keep a log (per a NYS Examiner I had). Log should show date of list, date of seach, results, who performed the search and who reviwed it.
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#1613123 - 10/06/11 01:23 PM Re: 314(a) Searches BC78a
BSA_in_depth Offline
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Joined: Jun 2006
Posts: 99
Texas
I use the 314 "Self Verification" feature on the website. You just verify that you have completed the searches and I print out a copy of the verification for retention.

The verification shows the transmission date, the dates and times that you accessed each list (person list and business list), the date you self-verified, the bank name, and the total subject records searched (the number of names on the list).

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#1613151 - 10/06/11 01:44 PM Re: 314(a) Searches BSA_in_depth
Doug Hendrickson Offline
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Doug Hendrickson
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We do the same; never had an issue.
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#1613178 - 10/06/11 02:08 PM Re: 314(a) Searches Doug Hendrickson
NewTooBSA Offline
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Joined: Nov 2005
Posts: 568
Texas
I believe the self verification on FinCen's 314(a) page was created so there is a uniform way to confirm the list was accessed and you are verifying that you completed the required search.

This should be adequate for your record keeping.

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#1613184 - 10/06/11 02:14 PM Re: 314(a) Searches NewTooBSA
BC78a Offline
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BC78a
Joined: May 2006
Posts: 311
New York
I filed the self verification is a folder by date - the NYS Examiners still wanted a log.
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#1613564 - 10/06/11 09:09 PM Re: 314(a) Searches BC78a
HallieK Offline
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HallieK
Joined: Jul 2001
Posts: 369
Oklahoma
I use the self verification feature as well. I download and save in a word file by date. Never had a problem with them.

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#1970159 - 10/17/14 02:49 PM Re: 314(a) Searches Cedar Point Guy
*W*W* Offline
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Posts: 835
I am a new BSA/AML software user. My software trainer told me we no longer needed to self verify on the 314a website because our software keeps a log of when the search was done and the results of the search.

Do you continue to self-verify if your software is completing the search for you?
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#1970171 - 10/17/14 03:10 PM Re: 314(a) Searches *W*W*
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
You must be able to document that the search was done. "Self Verification" is one method. However, the last two paragraphs on page 100 of the BSA/AML Examination Manual describe other methods. Compare the log provided by your software to the requirements spelled out in the manual. It may eliminate the need for self verification, but there's no way to know that without looking at the information contained in the log.
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#1970177 - 10/17/14 03:18 PM Re: 314(a) Searches Cedar Point Guy
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Gracias!
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