FinCEN released updated Section 314(b) guidance on June 12, replacing the agency's 2020 fact sheet.
The FinCEN 314(b) update: Fraud teams really can share more now ↗
What happened
- The updated guidance makes fraud offenses specified unlawful activities, so information sharing can cover suspected fraud without a money laundering connection.
- Reasonable suspicion is the threshold for 314(b) sharing under the updated guidance, not proof or a filed SAR.
- Associations of financial institutions can participate under 314(b).
- The FDIC, OCC, and Federal Reserve issued follow-up guidance in the weeks after FinCEN's release.
Why it matters to Signicat
- Expands the US fraud-sharing use case for identity-verification and fraud vendors whose customers are US financial institutions; Signicat's core markets are Europe, so direct relevance is limited.
- Content is a vendor thought-leadership piece that promotes consortium-based sharing; it does not name Signicat.
Evidence from the source (6 quotes)
- “Fraud offenses are specified unlawful activities (SUAs) under 18 U.S.C. § 1956, and that means the safe harbor applies.” source ↗
- “Reasonable suspicion is the threshold; not proof, not a completed investigation, not a SAR already filed.” source ↗
- “Associations of financial institutions can participate under 314(b).” source ↗
- “the FDIC, OCC, and Federal Reserve have all issued their own follow-up guidance reinforcing the same message” source ↗
- “Associations of financial institutions can participate under 314(b).” source ↗
- “Explore consortium membership.” source ↗
Fraud deepfake injectionAML KYB screeningThought leadershipRegulatory commentaryGlobal
5 of 5 facts verified against the source · confidence high · claude-haiku-5-5