Is there a requirement for financial institutions to do a follow up review on a customer that is reported to FinCen as a 314(a) hit? out side of the follow up review requirements if a SAR is filed on the customer.

No.

I suggest you document an enhanced due diligence effort where you give the customer and his activity a good once over and, if you do not find the basis for a SAR filing, write a memo to file saying why no SAR was filed. Note that if you get a hit, but never heard from the government, they probably found the person they were looking for someplace else. There is no implied need for a follow-up review.