{
  "body_html": "<h2>Information Sharing</h2>\n<p>When a <strong>314(a) request</strong> arrives from FinCEN, act immediately. Do not wait.</p>\n<ol>\n<li><strong>Retrieve the subject list</strong> as soon as the request arrives.</li>\n<li><strong>Note the response deadline.</strong> The window is typically two weeks from the issuance date.</li>\n<li><strong>Search all records</strong> — customer records, transaction records, and account files.</li>\n<li><strong>Match each subject</strong> by name, address, and identification number. Apply the date range specified in the request.</li>\n<li><strong>If you find a match,</strong> submit a <strong>positive match response</strong> to FinCEN within the required timeframe.</li>\n<li><strong>Check SAR obligation separately.</strong> A 314(a) match response does not replace a SAR. If the facts independently require a SAR, file it.</li>\n<li><strong>Document every search</strong> in the compliance file. Record:</li>\n</ol>\n<ul>\n<li>The date of the search</li>\n<li>The scope of records searched</li>\n<li>The names of all personnel who conducted the search</li>\n<li>Both positive and negative results</li>\n</ul>\n<p><strong>Confidentiality is mandatory.</strong> The request is confidential. Subject identities are confidential. All search results are confidential. Do not disclose any of this to customers, front-line staff, uninvolved employees, or third parties. Unauthorized disclosure can compromise an active law enforcement investigation.</p>\n<p><strong>314(b) voluntary program:</strong> Advanced Compliance Technology, Inc. does not currently participate. The BSA/AML Compliance Officer must evaluate participation if transaction volume, customer base, or risk profile changes in a way that would benefit from inter-institutional sharing.</p>",
  "narration_text": "When a 314(a) request arrives from FinCEN, act immediately. Do not wait.\r\n\r\nRetrieve the subject list as soon as the request arrives.\r\nNote the response deadline. The window is typically two weeks from the issuance date.\r\nSearch all records — customer records, transaction records, and account files.\r\nMatch each subject by name, address, and identification number. Apply the date range specified in the request.\r\nIf you find a match, submit a positive match response to FinCEN within the required timeframe.\r\nCheck SAR obligation separately. A 314(a) match response does not replace a SAR. If the facts independently require a SAR, file it.\r\nDocument every search in the compliance file. Record:\r\n   - The date of the search\r\n   - The scope of records searched\r\n   - The names of all personnel who conducted the search\r\n   - Both positive and negative results\r\n\r\nConfidentiality is mandatory. The request is confidential. Subject identities are confidential. All search results are confidential. Do not disclose any of this to customers, front-line staff, uninvolved employees, or third parties. Unauthorized disclosure can compromise an active law enforcement investigation.\r\n\r\n314(b) voluntary program: Advanced Compliance Technology, Inc. does not currently participate. The BSA/AML Compliance Officer must evaluate participation if transaction volume, customer base, or risk profile changes in a way that would benefit from inter-institutional sharing."
}