Safe Harbor?
Mary Beth Guard recommends that financial institutions file under 314(b) to share information whether they intend to share or not. Section 314(b) has several important benefits. First, it provides a safe harbor for crimes relating to money laundering. Guard finds that most crimes that involve money can somehow be tied to money laundering.
The second benefit is that you get a list of other institutions that have filed to share information. The best part about this list is that it includes the names of people to contact in other institutions. This can come in very handy!
Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 5, 6/03