FinCEN 314(a) requests, searched and proven: every possible match explained, every reply on two signatures inside the 14 days
Every subject searched and proven, every true match replied to inside the 14 days.
See one case, screen by screen ↓FinCEN 314(a) requests are the subject lists FinCEN posts every two weeks for banks and credit unions to search: accounts held in the preceding 12 months and transactions in the preceding six, with every positive match reported within 14 days. FinCEN 314(a) Requests does that work with eight agents. They read each list the day it posts, search six sources inside their windows, explain every possible match in one cited sentence and write a search record for every subject; a BSA Analyst confirms each match and the BSA Officer approves each reply.
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Every two weeks FinCEN posts a list of people and businesses that law enforcement is investigating for money laundering or terrorist financing. Each bank and credit union must search its records for accounts the subjects held in the preceding 12 months and transactions they made in the preceding six, including transactions with no account behind them, and report every positive match through FinCEN's secure system within 14 days of the posting. If nothing matches, the rule says not to reply at all.
So the BSA Analyst downloads the list, loads it into the core's search report, and searches every other system by hand: loan servicing, the safe deposit box system, the wire module, the official check and money order log, the cash log. Each system has its own name rules, and most match only exactly or on how a name begins. Fuzzy matches throw up dozens of look-alikes a list, each compared by eye across two or three screens. The reply is often marked without a second person checking, and for a list with no match, a printout and a signed checklist are the only proof the search was ever done. Examiners find the gaps: a closed account the current report left out, a member who uses a middle name, a walk-in's official check, a reply sent late, or a list seen by someone outside the BSA team.
Estimated split for one list of about 400 subjects at a credit union of Norrell's size, by hand and with the solution: about 35 look-alikes at about 12 minutes each, and about 4 hours of loading, searching and documenting.
Eight agents read the list, search six sources, explain each look-alike and prove the search; an analyst confirms, the BSA Officer approves.
Norrell Federal Credit Union serves 520,000 members from 38 branches. FinCEN posted list 2026-21 on Tuesday, October 20: 412 subjects, 318 people and 94 businesses, with replies due Monday, November 2. One business, Halcyon Ridge Logistics LLC, was confirmed and replied to on day 3. This is Friday, October 23, day 4 of 14.
The List intake agent reads list 2026-21 from FinCEN's 314(a) secure system, counts 318 people and 94 businesses, starts the 14-day clock and restricts the list to five named people: the two BSA Analysts, the BSA/OFAC Officer, the Deputy and the administrator. Internal audit has time-limited read access. Nobody else learns that FinCEN asked.
The Variant agent builds 2,936 name variants and normalizes 1,104 identifiers. The Search agent searches 927,067 records: accounts, loans and safe deposit box leases open now or closed since October 20, 2025, and wires, official checks and the cash log for six months, including official checks sold to non-members. The safe deposit box system timed out at 8:31 AM; the agent retried at 8:36 AM and finished. Of 1,118 name-similar records, 1,081 are set aside by rule NR-2 and 37 become possible matches.
NR-2 sets a record aside only when a date of birth or an SSN or EIN exists on both sides and every one conflicts. Never on a name alone. Priya re-checked the 2% sample, 22 records, and agreed with all 22.
Before anyone decides a match, the Coverage agent writes a receipt for every subject in every source: when it was searched, inside which window, and what it found. It will not call the list searched until every cell is covered, so the safe deposit box system counts only after its 8:36 AM retry. The record names the rules in force (name rules v7, NR-2 v3, scope v4) and waits for the BSA Officer's signature. Earlier records sit below it, including list 2026-20: 404 subjects, no match, no reply, signed.
The lists with no match are the ones with nothing to show an examiner. This is what there is to show.
A thin bar shows the reply window: day 4 of 14, the team's decision target on day 7, the officer's alert on day 10, due November 2. Below it the funnel: 412 subjects searched, 37 possible matches, 1 confirmed. 29 are ruled out and 7 wait. Each possible match is one plain sentence with the agent's proposal and its confidence, and the next step is named: start with D. Kenneth Whitcomb.
"D. Kenneth Whitcomb, safe deposit box lessee since 2018: date of birth matches, last four of SSN match." Proposal: confirm, 0.96.
Subject 147 on the list is WHITCOMB, Darnell Kenneth, also known as Ken Whitcomb. Member 6630-1842 is D. Kenneth Whitcomb, a member since 2011. Identifier by identifier: the name is close (the middle name used as the first), the date of birth of February 11, 1979 matches exactly, the SSN last four, 4417, match exactly, the address is close (Manchester, NH until August 2019 in the address history), and the list gives no other ID. Two match, two close, none differ, one missing.
Priya clicks the member's name and the source opens: member record 6630-1842 in the core banking system, identity verified at opening and again at the box lease on June 4, 2018, with Darnell Kenneth Whitcomb as the legal name on the identity verification record. The passage notes that her own view was logged inside the 314(a) compartment.
Safe deposit box 1184 at Concord Main, sole lessee since June 4, 2018, last opened September 30, 2026. A regular share account ending 5521, closed at the member's request on March 6, 2026, inside the 12 months. Nothing in loans, wires, official checks or the cash log, and 6 of 6 sources searched. The Match explainer proposes confirm at 0.96 with the reason codes CF-DOB and CF-SSN.
"The same person, most likely: two strong identifiers match." The agent proposes; it never confirms or rules out itself.
Priya confirms possible match 7 as subject 147, ticks CF-DOB and CF-SSN, and leaves a note for the BSA Officer: the member uses his middle name, lived in Manchester until 2019, box 1184 is current, and the share account closed inside the 12 months. The Reply agent drafts the reply. Nothing reaches FinCEN, the member or branch staff yet.
Renée reads exactly what the reply says before she approves it: match type account, the regular share account opened March 14, 2011 and closed March 6, 2026, the box 1184 lease since June 4, 2018, no transactions in six months, and the identifiers given at opening. She approves; the Reply agent submits it in FinCEN's secure system and records receipt 2621-147-A. The funnel now reads 412, 37, 2.
Only positive matches are reported, and each reply waits for a second person. When the Officer confirms a match herself, the Deputy, Curtis Vang, approves it.
The Hand-off agent drafts a referral for subject 147 and Renée opens a review: case CM-2026-0927, restricted to the BSA team, marked 314(a)-confidential, with the instruction not to contact the member or add notes to his record. The referral for Halcyon Ridge Logistics LLC, six outgoing wires totalling $412,600.00 between May 4 and October 2, 2026, failed to deliver at 4:41 PM the day before and waits on Retry delivery.
A 314(a) match is lead information. On its own it is not a reason to file a SAR, close an account or decline a transaction.
The same list, seen by the people who search it, approve it, test it, and must never see it — what each list cycle looked like, and what it looks like now.
Eight agents read the list, search six sources, explain each look-alike and prove the search; an analyst confirms, the BSA Officer approves.
Reads each list from FinCEN's 314(a) secure system on the day it is posted, counts people and businesses, starts the 14-day clock and restricts the list to the BSA team.
Builds name variants for every subject (the middle name as the first, initials, nicknames, spelling variants, business suffixes) and normalizes dates of birth, SSNs, EINs, addresses and IDs.
Searches the core, loans, safe deposit boxes, wires, official checks and the cash log inside their windows (12 months for accounts and leases, 6 months for transactions), retries a failed source and applies the set-aside rule NR-2.
Puts the subject and the record face to face, cites every value on both sides, writes the one-sentence explanation and a rationale, and proposes confirm or rule out with a confidence.
Writes a receipt for every subject in every source and the list's search record, and refuses to call a list searched until every cell is covered.
Drafts the reply for each confirmed subject (the account or the transaction, its number or date and type, the identifiers given at opening) and submits it in FinCEN's secure system after approval.
Drafts the referral to case management for each confirmed subject, with the guardrail that a list match alone is no reason for a SAR or a closure.
Logs every view of a list, a possible match or a receipt, and scans account notes, letters and member-facing channels for any 314(a) reference.
Approves every reply and signs every search record. The agents propose; a named person decides.
Ask in plain words about a subject, a possible match, a source or a rule, or say what to prepare. Every answer points to the list entry, the record or the rule it came from, and opens the item.
Why is D. Kenneth Whitcomb likely subject 147?
Two strong identifiers match. The list gives a date of birth of 02/11/1979 and an SSN ending 4417, and the member record has the same two. He uses his middle name, Kenneth, and lived in Manchester, NH until 2019, the city the list gives. His box 1184 lease is current and his share account closed on March 6, 2026, inside the 12 months. The confirm is yours.
Show that every subject was searched
The search record shows 412 of 412 subjects in 6 of 6 sources, each inside its window: 12 months for accounts, loans and boxes, 6 months for wires, official checks and the cash log. The safe deposit box system counted only after its 8:36 AM retry. Any subject's receipt opens on its own, matched or not.
Can we close Halcyon Ridge's account because of the match?
Not because of the list alone. A 314(a) match is lead information; it is not by itself a reason to file a SAR or close an account, and the request must stay confidential. The Hand-off agent drafted a referral so the BSA Officer can open a review of the activity on its own merits.
Prepare the NCUA examiner pack for list 2026-21
The pack holds the search record and its 412 receipts, the 37 possible matches with their evidence and decisions, the replies with their approvals and FinCEN receipts, the look-alike rule and sample, and the access log. Identifiers are cut to the last four, and records are kept 5 years. Choose the audience and build it.
12 screens from the working solution, on its sample data. Pick one to see it large.
The search scope, name rules, thresholds, clocks and reason codes every list runs on are settings. Each save is a new version, and scope, rule and threshold changes wait for the BSA Officer.
| Setting | Default | Choose from |
|---|---|---|
| Search scope | Six sources: accounts, loans and safe deposit box leases for 12 months; wires, official checks and the cash log for 6 months | Add a source · on a special request, FinCEN's scope and deadline override these for that list |
| Name variants | Middle name as first, initials, nicknames, one-letter spellings, word order, business suffixes | Name rules v7, with a nickname table of 1,240 pairs refreshed September 30, 2026 |
| Set-aside rule NR-2 | A date of birth or SSN/EIN on both sides, and every one conflicts; never on a name alone | A 2% sample of set-asides re-checked by an analyst on every list |
| Agent thresholds | Propose confirm at 0.90 or higher with two strong identifiers · rule out at 0.92 · bulk accept at 0.95 | Every change of prompt, model or threshold is a new version, tested on the year's lists and approved by the BSA Officer |
| Clocks and escalations | 14 days from posting; analysts decide by day 7; the Officer approves a confirmed reply within 1 business day | The Officer is alerted on day 10 if anything is open, the Deputy and the Chief Risk Officer on day 12 |
| Reason codes | CF-DOB, CF-SSN, CF-EIN, CF-ADDR, CF-ID to confirm | RO codes to rule out · INFO-ADDR and INFO-IMG to ask for information · RT-EVID and RT-FIELDS to return · OV-1 to OV-3 to override an agent |
| Identifiers by role | SSN and EIN last four to analysts; in full to the BSA Officer | Redaction profiles for NCUA and state examiners, internal audit and the BSA Officer |
| Retention | Search records, decisions and replies kept 5 years | List files encrypted in the compartment, never printed or emailed |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate, with the split shown · “typical” = published figures (31 CFR 1010.520: accounts maintained in the preceding 12 months and transactions in the preceding six months, positive matches reported within 14 days, and the request kept confidential; FinCEN 314(a) Fact Sheet, last updated October 13, 2026: lists every two weeks, no reply when nothing matches, 9,529 requests processed; FFIEC BSA/AML Examination Manual, information sharing; 31 CFR 1010.430 on five-year record retention). Norrell Federal Credit Union, its members, the subjects on the list, the account, box and receipt numbers and the people named on this page are fictional — characters and sample data in the working solution.
FinCEN 314(a) requests are the subject lists FinCEN posts every two weeks for banks and credit unions to search: accounts held in the preceding 12 months and transactions in the preceding six, with every positive match reported within 14 days. FinCEN 314(a) Requests does that work with eight agents. They read each list the day it posts, search six sources inside their windows, explain every possible match in one cited sentence and write a search record for every subject; a BSA Analyst confirms each match and the BSA Officer approves each reply.
Each subject must be searched against accounts maintained in the preceding 12 months and transactions conducted in the preceding six months, including transactions with no account behind them. The solution searches six sources: share, share draft and certificate accounts, loans, safe deposit box leases kept electronically, wire originators and beneficiaries, official checks and money orders sold to members and non-members, and the cash log. Each source shows its window, its record count and whether it answered.
Positive matches are reported through FinCEN's secure system within 14 days of the posting; if nothing matches, there is no reply. The window shows as a bar on every list, analysts aim to decide by day 7, and the BSA Officer is alerted on day 10 and the Deputy and Chief Risk Officer on day 12 if anything is still open. For a list with no match, the signed search record is the proof that every subject was searched.
Each possible match is one sentence, such as "D. Kenneth Whitcomb, safe deposit box lessee since 2018: date of birth matches, last four of SSN match", with the subject and the record face to face and every value cited. The agent proposes confirm or rule out with a confidence; the analyst decides with reason codes and can ask for information or ask the BSA Officer. Name-only look-alikes are set aside only under rule NR-2, and an analyst re-checks a sample of them on every list.
The list, the matches and the replies are visible to five named people, with internal audit on time-limited read access, and every view is logged. Branch staff who try to open a list see that it is not available to their role. A Confidentiality guard checks account notes, letters and member-facing channels every day for any mention of a list, and referrals to case management are restricted to the BSA team with an instruction not to contact the member.
Yes. The agents search, explain and draft; they never confirm, rule out, reply, sign, open a case, restrict an account or file a SAR. An analyst confirms each match with reason codes, the BSA Officer approves each reply, and the Deputy approves when the Officer made the decision. Every action is on the audit trail with who, when, why and the evidence.
An export pack for the period you choose: the search records and per-subject receipts, the possible matches with evidence and decisions, the replies with approvals and FinCEN receipts, the look-alike rule versions and samples, the access log and the settings and agent versions in force. It applies the audience's redaction profile (state examiner, internal audit and the BSA Officer have their own) and is sealed with a checksum.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your search scope, name rules, reason codes, roles and the systems your records live in. It goes live once every quality gate has passed.
Every fintech partner tested every quarter and tied out every day, with the evidence.
1-min demoBSA/AML Manual SearchCited BSA answers in under a minute, with your own procedure beside the rule.
1-min demoAML Alert TriageEvery alert read like a short brief, challenged, then closed or escalated in minutes.
1-min demoWe'll run FinCEN 314(a) Requests on a sample list against a copy of your own records.