What action should a credit union take after reporting a positive match to a 314(a) request?

After reporting a positive match to a 314(a) request, the appropriate course of action for a credit union is to take no further action regarding the customer or transaction that was reported. This is because the 314(a) request is a part of the FinCEN process aimed at assisting law enforcement in anti-money laundering efforts. Once a positive match is reported, it is essential that the financial institution refrains from further actions that could interfere with ongoing investigations.

This means that the credit union must avoid alerting the individual or entity in question, as this could compromise law enforcement activities. The response to the request, including the reported match, is designed to provide critical information to law enforcement while maintaining the confidentiality and integrity of the investigation. This adherence to protocol helps ensure that investigations are not hindered and that legal frameworks are respected.

While options such as notifying law enforcement, taking immediate legal action, or conducting an internal investigation may seem proactive, they can inadvertently disrupt ongoing investigations or violate established guidelines, leading to potential legal repercussions for the credit union. Thus, taking no further action after reporting aligns with compliance protocols under the Bank Secrecy Act and ensures that the institution supports law enforcement appropriately.