If yes, are you logging into FinCEN’s Secure Information Sharing System (SISS) and downloading each 314(a) list so the third party/core processor can run it against your customer records?
If you rely on a third-party/core processor to download the 314(a) lists on your behalf, you likely have a problem. While you can rely on them to run the searches against your customer records, each individual bank MUST still have a 314(a) contact person, and each bank/contact MUST log into FinCEN’s SISS themselves in order to download the 314(a) lists.
The issue is not necessarily that banks could receive different 314(a) lists. FinCEN confirmed that the same list is generally provided to all banks. The only time a list “may” differ is IF there’s a targeted, special list that pertains to a specific area. That said, we are not aware of any such targeted lists.
This issue is that you cannot allow a third party to download the lists that it receives from FinCEN, on your behalf. EACH bank MUST log in and download their own 314(a) lists. We don’t see a lot of issues with this but It might be a good idea to verify that you have a contact person in your bank, that they are receiving the communications from FinCEN and THEY are logging in to download the 314(a) lists.
Published
2021/04/06