1.2.5 314a FinCEN File Upload

The 314a Request Tracking process is a critical component of the FinCEN File Upload workflow.

It ensures that the uploaded files are properly reviewed and approved through a Four-eye approval process before the records are included in the screening process. The entire process includes multiple levels of approvals and validations to maintain accuracy and compliance with FinCEN requirements.

Request Tracking in 314a Tab:

Once the file is uploaded, all approval requests are tracked in the 314a Requests Tab within the private watchlist section.

Figure 1-4 View 314a Requests

Description of "Figure 1-4 View 314a Requests"

This tab allows users to:

• Download and review requests for accuracy and validate the file contents.
• Take Action (Approve or Reject) at each stage of the approval process.

  Figure 1-5 Take Action Window

  
  

  
  Description of "Figure 1-5 Take Action Window"

  
  

Request Actions:

• Approve: Once the request is approved by a user at any stage, the request moves to the next level (e.g., Manager to Supervisor).
• Reject: If the request is rejected at any stage, the request is on hold, and the uploaded file is excluded from further processing.

Four-Eye Approval Process

The Four-Eye approval process involves two levels of review (Supervisor and Manager) to ensure that all FinCEN file uploads undergo a thorough and compliant review before inclusion in the screening process.

Workflow Overview

The approval process for a FinCEN file upload follows a two level workflow:

1. Operator
2. Supervisor

Operator (Uploader):

The operator uploads the FinCEN file to the system. Once the file is uploaded, a request for approval is automatically generated and sent to the Manager for review.

Supervisor (Final Approval):

The Supervisor provides the final approval for the records to be included in the screening process. Only after the final approval, the records will be visible in the private watchlist screen and become available for screening.

Note:

The user groups are required to map to corresponding roles to users are given below.

• Operator: 314AOPERATOR
• Manager: 314AMANAGER
• Supervisor: 314ASUPERVISOR

Validation Rules:

Number of predefined validations are enforced during the file upload process to align with FinCEN's biweekly notification norms.

The validations rules:

• If a request is pending approval and the notification date falls within the last 14 days from the current notification date, no new uploads are permitted until the current request is approved or rejected.
• If the request was uploaded within the last 14 days, no new uploads are permitted until the current request is either approved or rejected.

Manager Review:

The request is sent to the Manager for initial review and approval. If approved, the request moves to the Supervisor for further review.

Supervisor Review:

The Supervisor performs a secondary check. After the final approval, the records are added to the private watchlist screen, ready for screening.