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Disclose Subject Appeared on FinCEN's 314a List?

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Question: 
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
Answer: 

Yes.

The 314(a) process is shrouded in a certain amount of secrecy, much of it voluntarily imposed by the industry. Regardless, unlike National Security Letters and Grand Jury Subpoenas, the "hit" can and should be mentioned in a SAR narrative where the bank has determined a SAR filing is necessary for other reasons.

First published on 11/04/2018

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