I think I've read somewhere or I've heard at a seminar or something that the Security Officer should run the 314a query. This is something that our Security Officer has been doing for years and we'd like to move it over to the BSA Officer's responsibilities. That's ok right?

I am the BSA officer and I conduct the 314(a) searches. We've never had any examiner say it wasn't okay.

314(a) is super-confidential, so I wouldn't have just any employee do it. I think it is fine to have the Security Officer do it, but I would have it be a dual process.

Here's what we do. The Central Ops Manager (also the Security Officer) and I (BSA and Compliance Officer) receive the FinCEN emails. Central Ops Manager checks the list, then writes Positive/negative on the front page with his initials and the date. Then I get the list, doa spot check of some of the names, then initial and date the front page. We only retain the front page of the list as evidence. I personally walk the remaining pages to the shred bin.

It's part of BSA, but there has been no regulatory expression of preference for who does the searches. In many banks it's a purely clerical function.

I appreciate all the input. I understand how important the list is and I always thought this was supposed to be like this for a dual control reason. I, as compliance officer, already check behind them (we do it all in the Patriot Officer Software)as reviewed.