FinCEN Records Search: Bank Obligations

Conducting a Records Search Pursuant to a FinCEN Request

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Question

When conducting a records search pursuant to a FinCEN request, what must a bank search?

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Explanations

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A. B. C. D.

B

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury responsible for collecting, analyzing, and disseminating financial intelligence information to detect and prevent financial crimes such as money laundering, terrorist financing, and other illicit activities.

When a bank receives a request from FinCEN to conduct a records search, the bank is obligated to comply with the request. The bank must search its records for information related to the request and provide that information to FinCEN within the specified time frame.

In terms of what records the bank must search, the answer is not A, B, C, or D. The answer depends on the specific request from FinCEN. FinCEN requests are usually targeted and specific to certain accounts or transactions that may be related to suspicious activity.

Therefore, the bank should search all records related to the requested accounts and transactions, which may include records from the previous five years, the previous 12 months, or a shorter or longer period, depending on the circumstances. The bank may also need to search records that are not electronically searchable, such as paper records or records stored on legacy systems.

In summary, the bank must conduct a thorough and comprehensive search of all records related to the specific request from FinCEN, regardless of whether the records are electronic or paper-based, and provide the information to FinCEN within the specified time frame.