BSA/AML/CFT Information Sharing: Risk Assessment
While information sharing under Section 314(b) of the USA PATRIOT Act is optional, it’s important that financial institutions who choose to participate give themselves “credit”. Regulators often point out just how valuable of a tool 314(b) information sharing can be. For instance, it can help mitigate an institution’s money laundering risk by uncovering activity that no single institution could detect on their own. That might include things such as multi-institution layering patterns, shared beneficiaries or transactors, coordinated cash structuring between institutions, etc. It can also help mitigate risks associated with fraud, terrorist financing, sanctions, high risk customers, etc. As such, institutions should be sure to address their 314(b) participation and the resulting risk mitigators in their risk assessment.
Kevin explains more in the video.
Published 2026/10/22
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).
