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#2225575 - 11/13/19 08:13 PM FiNCEN search question
GOWITHYOURGUT Offline
Member
Joined: Jul 2014
Posts: 78
Scenario: Pretty common name being searched for. Potential match according to FCRM program on a clients ACH Deposit BUT Middle initial does appear to be different however, search request also includes only first and last name as well. No way of knowing DOB or SS on individual named as sender for additional comparison.

Have not really had one quite like this and cannot find (or am overlooking) guidance on what step to take next. I know a "match" requires FinCen notification but not sure this is.

Any guidance appreciated, thanks!

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#2225604 - 11/13/19 10:44 PM Re: FiNCEN search question GOWITHYOURGUT
ColoradoAML Offline
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Joined: Mar 2018
Posts: 240
For clarification, what list are you screening this person against?

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#2225659 - 11/14/19 07:52 PM Re: FiNCEN search question ColoradoAML
GOWITHYOURGUT Offline
Member
Joined: Jul 2014
Posts: 78
314a - and at this point, after reading through the FAQ's, etc. - in a situation such as this, a phone call/e-mail would be the best and safest option.

Still open to others experiences if any, though.

Thanks!

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#2225661 - 11/14/19 07:58 PM Re: FiNCEN search question GOWITHYOURGUT
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,568
Galveston, TX
You need to review the 314(a) search criteria.
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#2225668 - 11/14/19 09:12 PM Re: FiNCEN search question GOWITHYOURGUT
GOWITHYOURGUT Offline
Member
Joined: Jul 2014
Posts: 78
I did, April 2018 FAQ's as well. #5 specifically - and if ever I read something completely backwards, it was this. frown

My apologies - and thank you to those who tried to respond (while shaking your heads, I'm sure!)

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