The CIP reg states that banks will check all new customers against any government provided lists. How are banks going to handle checking new customers against the freqeunt releases of 314 individuals and businesses.

This only refers to lists specifically designated as lists issued for 326 purposes. No such lists have been issued at present, we will be told when a "326" list is published, and the gov't advice has been to just state that when such lists are forthcoming you will comply with screening requirements.

The 314(a) lists are not "government lists" for purposes of CIP. The Section 326 lists will be designated as such when they are sent to us.

In many cases 314(a) lists are integrated with OFAC for a one-time screening and then the 314(a)s are removed. The 326 lists, when issued and so designated, will be similar I suspect, as to being integrated into existing procedures.

Not only do we not know what to expect, but we don't know when to expect them. It was commented on at the NRCC by John Byrne that these lists may or may never be produced. The 314(a) lists have done a lot of what the 326 lists were going to. So this is an unknown at this point. As noted, address it in a general sense for now.

Agree with all comments made. Just want to mention that some vendors have fully integrated programs that meet the ID verification requirements of Section 326, offer OFAC screening and 314a screening. And will incorporate the new 326 list when available.