FinCEN Updates Section 314(b): Guidance for Credit Unions

Financial crime continues to evolve, making timely information sharing between financial institutions an increasingly important component of fraud prevention and regulatory compliance. The Financial Crimes Enforcement Network (FinCEN) recently updated its guidance for the voluntary Section 314(b) Information Sharing Program. The National Credit Union Administration (NCUA) has shared this revised guidance with credit unions, providing additional clarity on how participating institutions can collaborate to detect fraud and combat financial crimes.

The updated guidance reinforces the value of information sharing as part of a strong Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance program.

What Is the Section 314(b) Information Sharing Program?

Section 314(b) of the USA PATRIOT Act allows registered financial institutions to voluntarily share information with one another for the purpose of identifying and reporting activities that may involve:

• Money laundering

• Terrorist financing

• Fraud

• Other financial crimes

  
  

By sharing that information, participating institutions may identify patterns and suspicious activity that may not be visible through their transactions alone. This collaboration helps strengthen fraud detection while supporting efforts to protect the financial system.

What's New?

FinCEN's revised guidance clarifies participation requirements and expectations for financial institutions that voluntarily participate in the program. It also reinforces existing registration, certification, and information sharing requirements.

Credit unions should review their participation status and confirm that all required registrations and certifications remain current.

What This Means for Your BSA Audit

As regulatory expectations evolve, credit unions should periodically review their BSA/AML programs to ensure they remain aligned with current guidance and industry best practices.

As part of Griffin & Furman's BSA testing engagements, we review several key areas related to Section 314(b), including:

1. Verify your credit union's FinCEN Section 314(b) certification is current.

2. Confirm required registrations have been maintained.

3. Review policies and procedures for alignment with current FinCEN guidance.

4. Evaluate how Section 314(b) participation supports your overall BSA/AML compliance program.

   
   

These procedures help identify potential compliance gaps and support readiness for future regulatory examinations.

Is Your BSA Program Up to Date?

Maintaining an effective BSA/AML program involves staying informed about evolving regulatory guidance and regularly evaluating internal controls, policies, and compliance procedures.

Griffin & Furman provides independent BSA testing and consulting services designed specifically for credit unions. Our team can help evaluate your Section 314(b) participation, identify opportunities to strengthen your compliance program, and support your institution’s ongoing regulatory readiness.

Contact our team to learn more about our specialized BSA testing services for credit unions.

Written by: Angela Warden