My AML vendor is extremely liberal in their interpretation of 314(b) and how it can be used, to the point that I've restricted viewing access for my staff. I would make sure you're coming to your own conclusions independently of theirs, and if I was tempted I'd probably have my legal council in the decision.
The real answer would probably have to be tested in court, but to add to what those above have said, plenty of people would argue that fraud may not provide safe harbor. The Clearing House even presented it as a recommendation to Congress.