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#188414 - 05/10/04 05:41 PM Proof of 314a Search
HR Banker Offline
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Joined: Oct 2002
Posts: 1,027
Is it stated anywhere that you need to have proof that you performed the searches? If so how do you do this? Does each 314a list have to be kept for a certain period of time or when you've completed the search can the list be shredded?

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BSA/AML/CIP/OFAC Forum
#188415 - 05/10/04 06:16 PM Re: Proof of 314a Search
Tink Offline
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Joined: Apr 2004
Posts: 59

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#188416 - 05/10/04 06:22 PM Re: Proof of 314a Search
La. Lady Offline
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La. Lady
Joined: May 2001
Posts: 1,873
There are no specific recordkeeping requirements, however, how will you ever prove that you did do it. We keep a record by using an internal form. Each area is to indicate whether or not there were hits and to initial the form. This form is maintained for an appropriate time or at least until the examination is completed.

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#188417 - 05/10/04 06:34 PM Re: Proof of 314a Search
HR Banker Offline
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Joined: Oct 2002
Posts: 1,027
Thanks. I guess I'll be looking for more drawer space to continue keeping the lists!

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#188418 - 05/10/04 06:51 PM Re: Proof of 314a Search
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
ltackett,
Please take a look at the post Andy added to the linked thread a few months later. The OCC guidance suggests a couple of approaches that do not involve keeping the lists - if you are a National bank, you're home free if you take one of those. If you are Fed or FDIC, you might call the EIC from your last exam and ask if one the approaches outlined there would be acceptable.
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#188419 - 05/10/04 07:20 PM Re: Proof of 314a Search
Fork Ate Spoon Offline
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Fork Ate Spoon
Joined: Aug 2003
Posts: 2,261
Between Here and There
We use our CIF file to search against the 314a list through Homeland/World Tracker. And as for wire transfers, we use our Wire Transfer system (by Wayne Barnett), which has a 314a search option (really cool). Our entire 314a search takes a max of about 10 minutes. We will make (and keep) copies of the searches and indicate if there were any matches or not.

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