What must a financial institution do if it finds a match on a 314(a) list, and how quickly?

If your institution finds an account or transaction for a named subject, it must report to FinCEN in the manner and time frame the request specifies (31 CFR 1010.520(b)(3)(ii)). Under FinCEN's 314(a) process, that means responding through the secure portal within two weeks of the request's posting date.

What the rule says:

• Report a match to FinCEN in the manner and time frame specified in FinCEN's request: the subject's name, the account number (or, for a transaction, its date and type), and any Social Security number, taxpayer identification number, passport number, date of birth, address, or similar identifying information provided when the account was opened or the transaction was conducted (31 CFR 1010.520(b)(3)(ii)).
• Search expeditiously on receipt. Unless the request says otherwise, the search only needs to cover current accounts, accounts maintained during the preceding twelve months, and transactions or fund transmittals during the preceding six months that the institution is required to record or that it records and maintains electronically (31 CFR 1010.520(b)(3)(i)). For this purpose, a transaction does not include any transaction conducted through an account (31 CFR 1010.505(d)(2)).
• Do not disclose to anyone that FinCEN requested or obtained information, except to FinCEN or the requesting Treasury component, the law enforcement agency named in the request, or, for a foreign law enforcement agency's request, the U.S. law enforcement attaché named in the request, and except as necessary to comply with the request (31 CFR 1010.520(b)(3)(iv)(B)(1)). An institution authorized to share information under 31 CFR 1010.540 may share information about a named subject under that section, but the sharing must not disclose that FinCEN requested information about that subject (31 CFR 1010.520(b)(3)(iv)(B)(2)).
• Designate one person as the point of contact for the request and for future FinCEN requests (31 CFR 1010.520(b)(3)(iii)).
• A match does not by itself require the institution to act or refrain from acting on the account or transaction, or to decline to open an account or engage in a transaction with the named party. Unless the request says otherwise, it also does not require reporting on future account opening activity or transactions (31 CFR 1010.520(b)(3)(v)).

What to do:

• Log the portal posting date and calendar two weeks from it. The rule defers to the request on timing, so if the request states a different manner or deadline, follow the request.
• Document the search and its results. If nothing matches, FinCEN's fact sheet instructs the institution not to reply.

Timing: the regulation sets no fixed number of days itself. It points to the request, and FinCEN's fact sheet describes two weeks from posting for positive matches.

Sources

1. 31 CFR § 1010.520(b)(3)(ii): https://www.law.cornell.edu/cfr/text/31/1010.520
2. FinCEN 314(a) Fact Sheet (last updated Oct. 13, 2026): https://www.fincen.gov/system/files/shared/314afactsheet.pdf
3. 31 CFR 1010.520 (eCFR): https://www.ecfr.gov/current/title-31/section-1010.520

This answer is general information, not legal advice. Forteris is not a law firm.