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FinCEN 314(a) Screenings for Employees?

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Question: 
I have two questions regarding FinCEN 314(a) screenings. Is the institution's employee required to be screened against the 314(a) list? Are there any regulatory or legal issues with screening employees against the 314(a) list?
Answer: 

To the extent that the employee maintains an account with you, yes. Status as an employee affords them no exception from the 314(a) process.

First published on 09/23/2018

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