What are the difference between the Control List and the FinCEN Advisories?

Question:

What are the difference between the Control List and the FinCEN Advisories ?

Answer:

The Control List was initiated before rules were implemented on Section 314 of the USA PATRIOT Act. The new procedures for government information requests to financial institutions regarding money laundering or possible terrorist activity are covered in Section 314(a) of the PATRIOT Act and the corresponding BSA regulation 31 CFR 103.100 There is currently a moratorium on information requests under Section 314(a) while they reexamine the procedure and determine whether it can be improved.

The Control List is now obsolete, but there are several important similarities between the Control List and information requests under Section 314(a). The most important is that the request is extremely confidential. The names are not published. They are transmitted directly to financial institutions from FinCEN. Only those with a need to know within the institution should know of the request.

First published on BankersOnline.com 2/3/03