Brown Brothers Harriman Case Study

How BBH has leveraged its investment in sanctions filtering to fully automate the 314(a) process

The Challenge and Legal Requirements

Under 314(a), all federal agency requests for information are processed by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) agency. Brown Brothers Harriman (BBH), like any other financial institution in the U.S., receives a 314(a) request for information from FinCEN every two weeks. The regulation requires that financial institutions search their customer account records for the current and preceding twelve month period and transactions conducted for the past six month period against those lists for possible data matches. They then have fourteen calendar days to report their results to FinCEN…