What is the required action for credit unions when new 314(a) lists are posted?

The required action for credit unions when new 314(a) lists are posted is to query their records for data matches within specified time frames. This process is part of compliance with the Bank Secrecy Act (BSA) and involves reviewing customer accounts and transactions against names provided on the lists published by the Financial Crimes Enforcement Network (FinCEN).

By performing this query, credit unions ensure they are proactive in identifying potential matches related to suspected money laundering or terrorist financing activities. If a match is found, they are then required to take appropriate action, which may include filing a Suspicious Activity Report (SAR) or notifying authorities, depending on the situation. This step is essential in supporting law enforcement efforts to combat financial crimes.

The emphasis on timely querying underlines the importance of swift action in mitigating risks associated with potential criminal activities linked to the entities listed. Institutions are typically given specific time frames within which to conduct these checks to ensure compliance and assist in any necessary law enforcement investigations.