FinCEN Match Menu

This document provides technical guidance for users of the FinCEN Match Menu within the FLEX system. The FinCEN Match Menu assists financial institutions in complying with Bank Secrecy Act (BSA) regulations by facilitating the search, reporting, and management of suspicious activity related to money laundering and fraud.

1. Overview of FinCEN Compliance

The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, mandates financial institutions to:

• Record and report suspicious activities indicative of money laundering and fraud.
• Search all internal records for potential matches against the official FinCEN list.
• Generate reports of identified matches for submission to FinCEN.

The FLEX system’s FinCEN Match Menu provides tools to streamline these compliance activities.

2. Accessing the FinCEN Menu Options

The FinCEN menu options are accessible via the following navigation path within the FLEX system’s “Internal Audit” section:

• Internal Audit
  • Bad Address
  • Check Fraud
  • Check Kiting
  • Dormant Accounts
  • FinCEN
    • Download FinCEN Match File
    • FinCEN Account Bypass Maintenance
    • Point of Contact Information
    • Print FinCEN Match Report
    • Search FinCEN Matches

3. FinCEN Match Menu Functions

The FinCEN Match Menu provides five primary functions to manage FinCEN compliance:

3.1. Download FinCEN Match File (FC3000C)

This function compares the official FinCEN file (located in the OFAC folder) with the credit union’s database to identify potential matches.

• Purpose: To generate a combined file of potential matches for further processing.
• Process:
  1. The system reads the FinCEN file from the \OFAC\ folder.
  2. This data is compared against the credit union’s internal database.
  3. A combined file is created and automatically renamed to FINCEN.TXT.
  4. The FINCEN.TXT file must be copied to the server at the file path: \OFAC\FINCEN.TXT.
• User Interface Fields:
  • Is File Ready To Process?: Select “Yes” or “No” to indicate the file’s readiness for processing.
  • Letters to match in First Name: Specify the number of characters in the first name that must match for a record to be considered a potential match.
• Action: Click Process to initiate the file download and comparison.

3.2. Print FinCEN Match Report (FC3010C)

This function generates a printable report of identified FinCEN matches and their associated tracking numbers.

• Purpose: To produce a report required for submission to the FinCEN secured website.
• Prerequisite: This option should be executed only after the “Download FinCEN Match File” option has been completed to ensure the report reflects the most recent data.
• User Interface Fields:
  • Letters to match in First Name: Enter the number of letters in the first name that must match for inclusion in the report.
• Action: Click Process to generate and print the list of possible matches.

3.3. Point of Contact Information

This function allows users to maintain the required point-of-contact information for FinCEN reporting. This information will appear on the generated name match report.

• Purpose: To provide the contact details of the individual responsible for name searches at the institution, as required by FinCEN.
• User Interface Fields (Example Fields):
  • Name
  • Street Address
  • City/State/Zip
  • Phone
  • Email
• Actions:
  • Save: To save any changes made to the contact information.
  • Refresh: To revert to the previously saved contact information.

3.4. Search FinCEN Matches

This function enables users to perform an on-demand search for a single member against the entire FinCEN file.

• Purpose: To quickly check a specific member for potential FinCEN matches without generating a full report.
• Output: Results are displayed directly on the screen; no report is generated.
• User Interface Fields:
  • First Name: Enter the member’s first name.
  • Last Name: Enter the member’s last name.
  • Business Name: Enter the business name (if applicable).
  • Starts With (Checkbox): Select this option if the name must begin with the specified number of characters.
  • Max Differences: If “Starts With” is checked, enter the maximum number of character differences allowed for a match.
• Action: Click Search to execute the query.

3.5. FinCEN Account Bypass Maintenance

This function allows the credit union to manage a list of member accounts that should be excluded from the FinCEN match program.

• Purpose: To prevent repeat false positive matches from appearing on the FinCEN match report.
• Functionality:
  • Add:
    1. Click Add.
    2. Key in the account number.
    3. Press Save.
  • Delete:
    1. Highlight the member account to be deleted.
    2. Press Delete.
• User Interface Fields (Example):
  • Account: Displays the account number.
  • Name: Displays the name associated with the account (e.g., JOHNSON, ANNA).