Still Some 314(a) Problems

Even after "fixing" the initial problem with Section 314(a), the HOTLINE has been hearing of problems still attached to the revised data-match program.

The data-match program that requires financial institutions to search their last twelve months records for accounts with listed names and their prior six months records for transactions with entities started last November. A moratorium was quickly put into effect until the concerns of banks could be addressed because of the flood of requests that was unleashed by law enforcement. In March, after altering some of the procedures, the "information sharing" was restarted.

However, two banking associations recently wrote to Treasury informing them that "?recent requests are overly broad, unduly burdensome, and appear to be used more for general investigation of criminal activities rather than truly focused on terrorism and money laundering." Treasury says it will continue to try to find a solution that is workable for the industry.

Copyright © 2003 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 13, No. 2, 4/30