What further actions should the credit union take when they have a positive match to the 314(a) requests?

When a credit union has a positive match to a 314(a) request, the appropriate action is to ensure compliance with the requirements set forth by the Financial Crimes Enforcement Network (FinCEN). The 314(a) program helps law enforcement agencies identify and investigate financial crimes, such as money laundering and terrorist financing, by allowing them to request information from financial institutions.

Taking no further action is not the correct approach in this case, as the institution is obligated to respond appropriately to the notification of a potential match. The credit union is typically required to maintain confidentiality regarding the match and to avoid notifying the member involved or engaging in unnecessary actions that could compromise the investigation. Instead, it must adhere to the guidance provided in the 314(a) request, which usually involves a review of the account activity and possibly continuing to monitor the transaction activities of the individual.

The correct response would involve notifying law enforcement or conducting any necessary internal investigations as prescribed by established protocols. This ensures that the financial institution is complying with regulations while also supporting law enforcement agencies in their efforts to combat financial crime.