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This document addresses the temporary moratorium on information requests under Section 314 of the USA PATRIOT Act, detailing the process for financial institutions to communicate about suspected money
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How to fill out joint agency notice

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How to fill out Joint Agency Notice - Treasury Issues Moratorium on Section 314(a) Information Requests

01
Identify the relevant financial institution or entity subject to the Joint Agency Notice.
02
Review the notice to understand the implications of the moratorium on Section 314(a) information requests.
03
Gather any necessary documentation or information required to comply with the request prior to the moratorium.
04
Communicate with compliance or legal teams within the organization for guidance on adapting to the moratorium.
05
Document any requests made prior to the moratorium and ensure records are kept up to date during this period.
06
Stay informed about updates or extensions related to the moratorium by monitoring official communications from the treasury and regulatory agencies.

Who needs Joint Agency Notice - Treasury Issues Moratorium on Section 314(a) Information Requests?

01
Financial institutions and entities that are normally required to respond to Section 314(a) information requests.
02
Compliance officers and legal teams within these institutions who must adapt their strategies to the moratorium.
03
Regulatory agencies and oversight bodies monitoring the implementation of the moratorium.
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The financial institutions must query their records for data matches, including accounts maintained by the named subject during the preceding 12 months and transactions conducted within the last 6 months. Financial institutions have 2 weeks from the posting date of the request to respond with any positive matches.
The 314(a) program requires certain financial institutions, upon receiving an information request from FinCEN, to search their records and identify if they have responsive information with respect to the particular investigative subject.
The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation.
A FinCEN 314(a) Request contains the names and addresses of subject individuals and/or entities that are suspected to be involved in money laundering or terrorist activities, along with any available identifying data that can be used by FIs to search their records.
USA PATRIOT Act Section 314(b) permits financial institutions, upon providing notice to the United States Department of the Treasury, to share information with one another in order to identify and report to the federal government activities that may involve money laundering or terrorist activity.
Section 314(a) is part of the USA Patriot Act that enables financial institutions (FIs) and law enforcement to work together to fight money laundering and terrorist activity. Through 314(a), law enforcement can retrieve key information from FIs.
If an FI gets a positive match, it must be reported to FinCEN within 14 days unless otherwise noted in the formal information request. The 314(a) Secure Information Sharing System (SISS) is a web-based tool where FinCEN posts subject lists. Every two weeks, notifications are sent through the system to FIs.

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The Joint Agency Notice refers to a directive issued by financial regulatory agencies, indicating a temporary suspension of information requests under Section 314(a) of the USA PATRIOT Act, which allows for the sharing of information related to suspicious activities among financial institutions.
Financial institutions that are normally required to respond to requests under Section 314(a) are the ones impacted by the moratorium; however, during this temporary period, they are not obligated to submit information as requested.
During the moratorium, financial institutions do not need to fill out or submit any Joint Agency Notices related to Section 314(a) information requests, as such requests are suspended.
The purpose of the moratorium is to alleviate the burden on financial institutions and to streamline procedures, allowing agencies to reassess and enhance the effectiveness of information sharing processes under Section 314(a).
Typically, information to be reported would include details about individuals or entities suspected of money laundering or terrorist financing; however, during the moratorium, no reporting is required.
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