Answer:
There is, of course, the general FinCEN regulatory requirement to retain certain BSA-related records for five years, which will apply to records relating to FinCEN 314(a) requests. That said, 31 CFR section 1010.520 does not specifically require you to retain 314(a)-related records, but FinCEN does recommend that you maintain a record of the date of any 314(a) request you receive, the tracking numbers within the request, and the date the bank completed its search to satisfy the request. Also suggested is a record of the date on which the bank reported any match to FinCEN. FinCEN also recommends that you maintain information concerning identified accounts and transactions in a way that allows them to be easily accessed if requested by law enforcement (but read the cautionary note below).
There is no requirement (nor is there a prohibition) that you maintain copies of search requests. If you do retain these requests, they (and all the rest of your 314(a) information) are expected to be retained in a secure and confidential manner. I recommend they be kept under lock and key, with access restricted to department personnel and to audit and examination personnel to the extent needed for completion of their responsibilities.
print
share