314(b) Info Sharing – How Much Can We Share?
Answer by John Burnett, BOL Guru Guru Bios
Question: How much information can a financial institution share with another financial institution that is under the 314(b)?
Answer: The only information you can share is information "regarding individuals, entities, organizations, and countries for purposes of identifying and, where appropriate, reporting activities that the financial institution or association suspects may involve possible terrorist activity or money laundering." [31 CFR 103.110(b)] There may be other reasons that you might have a legitimate purpose for sharing certain other information, such as information involving fraud or check kiting, etc., but those exchanges fall outside the "safe harbor" provision provided for so-called "314(b)" sharing under section 103.110.
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