On June 12, 2026, FinCEN issued an updated 314(b) Fact Sheet that continues its efforts to provide greater clarity on the scope of information sharing under Section 314(b) of the USA PATRIOT Act. The guidance reinforces FinCEN’s goal of encouraging institutions “to promote greater information sharing between and among financial institutions to identify fraud, money laundering, terrorist financing, [and] narcotics trafficking.” Long considered one of the most underutilized tools in the BSA/AML toolkit, Section 314(b) is taking on renewed importance, with the updated guidance making clear that expectations around inter-institutional collaboration have evolved.
For financial institutions, the guidance reinforces the opportunities for collaborative information sharing within the existing regulatory framework. The question is no longer whether institutions can share information, but whether they are equipped to do so at the speed, scale, and precision today’s threat environment demands.
Strengthening Investigations Under Section 314(b)
FinCEN’s updated Fact Sheet meaningfully expands the operational envelope of Section 314(b). Six clarifications stand out for risk and compliance leadership:
- Real-time sharing is expressly permitted.
FinCEN confirms institutions “may share information in real time as activity is occurring.” This validates collaborative workflows that operate at transaction speed — not days or weeks after the fact.
- Fraud is squarely in scope.
Because fraud offenses such as mail, wire, bank, securities, healthcare, computer-intrusion fraud, and more are Specified Unlawful Activities (SUAs) for money laundering purposes, suspected fraud is sharable under 314(b), without needing to first identify specific laundered proceeds.
- No prior relationship required.
A registered institution can share information with another registered institution, even without an existing customer connection. Receiving institutions can feed that intelligence directly into transaction monitoring systems and customer due diligence processes.
- Broader data types are explicitly endorsed.
FinCEN explicitly includes transaction data, video surveillance footage, IP addresses and geolocation, device identifiers, account decisioning records, transaction monitoring alerts, and behavioral indicators such as geographically improbable logins and multiple accounts with overlapping identifiers.
- Method-agnostic and group sharing are fully permitted.
Electronic platforms and multi-institution group sharing is both explicitly within the safe harbor. The BSA “imposes no limitations on how information can be shared.” Written, verbal, and electronic platform-based sharing are permitted, as is sharing within a group of participating institutions or associations.
- Joint SARs are encouraged.
Where collaboration produces a clearer picture of suspicious activity, FinCEN explicitly endorses joint filings resulting in higher-quality, corroborated SARs that law enforcement can act on, and that examiners recognize as a marker of program maturity.
Why This Matters for Financial Institutions
Financial crime risk doesn’t respect institutional boundaries. A single mule network, business email compromise scheme, or trade-based laundering typology routinely touches multiple institutions with each seeing only a fragment of the picture. Effective 314(b) collaboration directly addresses this challenge.
The benefits of 314(b) information sharing extends across the enterprise, reinforcing a shift to more proactive, intelligence-led programs reinforcing 314(b) purpose of detecting and reporting money laundering and terrorist financing. Institutions reduce cross-institution financial crime exposure, improve visibility into customer and counterparty risk, strengthen regulator and board narratives, and identify criminal networks and emerging typologies earlier, helping mitigate both capital and reputational risk. Collectively, these outcomes represent a meaningful shift from reactive case management to proactive, intelligence-led programs.
The Operational Gap Most Institutions Still Face
The Federal Reserve’s 2026 Risk Officer Survey shows 23% of institutions remain unenrolled in 314(b), and fewer than one in five share information on a regular basis. For most institutions, 314(b) remains a reactive tool activated when an investigator already has a specific suspicion, not a continuously operating intelligence layer.
The manual approach, involving one analyst, one email, one counterparty, cannot keep pace with criminal networks that deliberately spread activity across institutions to evade any single program’s detection threshold. With FinCEN now affirming real-time, group-based, electronic-platform sharing, including the use of transaction monitoring alerts and device-level intelligence, examiners and law enforcement will increasingly view the absence of scaled collaborative capability as a program weakness.
Three Questions Worth Asking Now
For financial institutions reassessing their 314(b) approach in light of this guidance, key questions include:
- Are we registered, and is our participation actually operational, or is 314(b) effectively dormant in our program?
- Can we share and consume intelligence in real time, at scale, and across a meaningful network or are you still limited to bilateral email exchanges?
- Can we evidence the impact of 314(b) participation in our SAR quality, fraud loss reduction, and alignment with the AML/CFT National Priorities — in a form our board and examiners will recognize?
For institutions aiming to strengthen their fraud prevention programs, the answer increasingly lies in purpose-built financial crime management solutions for secure, scalable collaboration.
Operationalizing 314(b) at Scale
Collective defense is clearly supported by regulation, demanded by the threat environment, and enabled by scalable technology.
Since 2015, Nasdaq Verafin’s FRAMLxchange has enabled registered financial institutions to collaborate securely under the 314(b) safe harbor, turning information sharing into a real-time, operational capability. Through the network, investigators can exchange intelligence, share supporting documentation, and build joint cases with trusted peers, strengthening investigative context and helping surface financial crime that would otherwise remain fragmented across the financial system.
In this new environment, 314(b) is no longer an underutilized capability, it is a strategic requirement. Institutions that can operationalize information sharing at scale will be better positioned to detect, investigate, and disrupt financial crime.
About the Author
CHUCK TAYLOR
JD, CAMS, CAFP, Head of Commercial Strategy, Nasdaq Verafin
Bringing a wealth of knowledge and experience from previous executive roles in consultancy and banking, Chuck now serves as the Head of AML Commercial Strategy for Nasdaq Verafin and is tasked with aligning sales execution with product vision and go-to-market strategies, empowering sales teams, and unlocking growth across diverse customer segments. Chuck works closely with product management teams, business leaders, and clients to ensure that the company’s offerings are aligned with current regulatory standards and effectively address the evolving challenges in the financial services industry.
In addition, Chuck serves as a subject matter expert on AML regulations, industry trends, and best practices for financial crime prevention for Nasdaq Verafin. His role involves providing strategic insights to enhance the company’s financial crime solutions and assisting clients in navigating complex compliance requirements.
