A 314(a) request is when US law enforcement, through FinCEN, sends banks a list of names tied to serious money laundering or terrorism and asks them to search their records for a match. It turns your own customer and transaction data into a search tool for live federal cases, and a hit can be your first link between a customer and a real investigation.
What is a 314(a) request, in plain English?
A 314(a) request is a channel that lets US law enforcement reach into the banking system to find where a suspect touched it. When investigators are working a serious money laundering or terrorism case, they send a list of names through FinCEN, which distributes it to financial institutions. Each institution searches its own records and reports back only whether it has a match.
In effect, it turns every participating bank's customer and transaction data into a search tool for active federal investigations. Law enforcement does not get to browse your records; they learn which institutions hold a relationship with the named subject, then follow up through separate legal process like a subpoena to get the detail.
For an institution, a 314(a) hit can be the first link between a customer you already bank and a live criminal case you knew nothing about. It is not proof of wrongdoing, but it is a strong signal that the relationship deserves a closer look, and it must be handled quietly and correctly.
How a 314(a) request is handled
- Receive — FinCEN sends the list. A batch of names tied to serious money laundering or terrorism arrives through the secure FinCEN channel.
- Search — Check your records. Search accounts and transactions over the set look-back window for any match to the named subjects.
- Report — Return only the hits. Report positive matches to FinCEN, usually within 14 days; you do not report the misses.
- Review — Do not tip off. Review the relationship internally without alerting the subject or freezing anything on a match alone.
314(a) vs 314(b)
What changes | 314(a) request | 314(b) sharing |
Who initiates | Law enforcement, via FinCEN. | Financial institutions, with each other. |
Mandatory? | You must search and report matches. | Voluntary participation. |
Direction | Government asks banks to search. | Banks share information peer to peer. |
Purpose | Locate a subject in the banking system. | Piece together a pattern across institutions. |
What it looks like in practice
In practice
A 314(a) batch arrives naming several subjects in a money laundering investigation. The BSA team runs the names against accounts and transaction history over the required look-back period. One subject matches a customer who has banked with the institution for two years.
The team reports the match to FinCEN within the deadline and opens an internal review. They do not call the customer, do not close the account, and do not freeze funds, because a 314(a) match is not by itself grounds for any of that and tipping off the subject could obstruct the case. The review pulls the customer's activity, and the pattern it surfaces gives the team a strong reason to consider filing a SAR.
Why it matters for operators
A 314(a) request is a rare direct line into live federal casework, and how you handle it is closely watched. The obligations are specific: search your records over the set look-back window, report only the hits within the deadline, and keep the whole thing confidential. Missing the deadline, searching incompletely, or tipping off the subject are all failures an examiner will note.
It also feeds your own risk picture. A match is not an automatic SAR and not grounds to freeze or exit on its own, but it is a strong reason to review the relationship, because law enforcement has independently connected that name to serious crime. The discipline is acting on the signal internally while doing nothing that alerts the subject.
What to watch when one arrives
- Deadline. Matches must be reported to FinCEN within the set window, usually 14 days; a missed deadline is an exam finding.
- Look-back scope. Search the full required period across accounts and transactions, not just current customers.
- Do not tip off. A match is not a reason to contact, freeze, or exit the customer; doing so can obstruct the investigation.
- Report only hits. You report positive matches, not the searches that came back empty.
- Match is not a SAR. A 314(a) hit is a strong reason to review, but the SAR decision rests on your own analysis.
Quick questions
Is responding to a 314(a) request optional?
No. Searching your records and reporting matches is mandatory for participating institutions, on the deadline FinCEN sets. This is a key contrast with 314(b), which is voluntary information sharing between banks.
Does a 314(a) match mean I have to file a SAR?
Not automatically. A match is a strong reason to review the relationship, because law enforcement has tied the name to serious crime, but the SAR decision comes from your own investigation of the customer's activity.
Can I freeze the account or contact the customer on a match?
No. A 314(a) match alone is not grounds to freeze funds or exit the customer, and contacting them could tip off the subject and obstruct the case. You review internally and keep it confidential.
What do I actually report back to FinCEN?
Only the positive matches, within the deadline. You do not report searches that found nothing. Law enforcement then follows up on the hits through separate legal process such as a subpoena to obtain records.
How is 314(a) different from 314(b)?
314(a) is law enforcement, through FinCEN, asking banks to search their records and report matches. 314(b) is voluntary sharing of information between financial institutions themselves. Do not confuse the two; one is mandatory and government-driven, the other is voluntary and peer-to-peer.
Go deeper
- FinCEN ↗ — The US financial intelligence unit. Bank Secrecy Act rules, advisories, and SAR and CTR guidance.
- FFIEC BSA/AML Examination Manual ↗ — The manual US examiners use to assess BSA and AML programs.