1.2.6 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 1-5 View 314a Requests

Description of "Figure 1-5 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 1-6 Take Action Window

  
  

  
  Description of "Figure 1-6 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.

Note:

For the following search fields, Data Type and Character Length information can be found in the Field Specification Guide on the MOS page.

Table 1-3 List of fields for Person FinCEN File

Record Name	Description	Mandatory Field	Matching attribute	Accepted Values
Last Name	Enter The Last Name.	Yes	Yes	-
First Name	Enter The First Name.	Yes	Yes	-
Middle Name	Enter the Middle Name.	-	-	-
Suffix	Enter Suffix.	-	-	-
Alias Last Name	Enter the Alias Last Name.	-	-	-
Alias First Name	Enter the First Name.	-	-	-
Alias Middle Name	Enter the Alias Middle Name.	-	-	-
Alias Suffix	Enter Alias Suffix	-	-	-
Number	Enter the number used to identify the individual.	-	Yes	-
Number Type	Enter the document used to identify the individual.	-	-	The following identification types are accepted: Passport SSN/ITIN EIN TIN Driver's License
DOB	Enter the individual date of birth.	-	Yes	-
Street	Enter the Street Name.	-	-	-
City	Enter the city where the individual resides or the state in which the entity is registered.	-	Yes	-
State	Enter the state where the individual resides or the state in which the entity is registered.	-	-	-
ZIP	Enter the Country ZIP code.	-	-	-
Country	Enter the code of the country where the individual resides	-	Yes	ISO2 country codes configured in the master data in the Oracle Financial Services Customer Screening Cloud application are accepted.
Phone	Enter the Phone Number.	-	-	-
Electronic Address	Enter the email, IP address or website address for the private watchlist records. Note:This field is used as a matching attribute for 314a screening .	-	Yes	-
Electronic Address Type	Select the list of address types from the drop-down list to include information about email IP address and Websites. Note:This field is applicable for Individuals and Entities on the 314a Watchlist only.	-	-	The list of following values are accepted: Secure E-Mail Address Internet Protocol Address E-Mail Address Web Site Address IP Address
Tracking Number	Enter the Tracking Number. Note:This field is applicable for Individuals and Entities on the 314a Watchlist only.	Yes	-	-

Table 1-4 List of fields for the Business FinCEN File

Record Name	Description	Mandatory Field	Matching attribute	Character Length	Data Type	Accepted Values
Business Name	Enter The Business Name.	Yes	Yes	250	String	-
DBA Name	Enter The Doing Business as or Trading business Name.	-	-	4000	String	-
Number	Enter the number used to identify the entity.	-	Yes	100	String	-
Number Type	Enter the document used to identify the entity.	-	-	500	String	The following identification types are accepted: Passport SSN/ITIN EIN TIN Driver's License
Incorporated	Enter the Incorporated.	-	-	500	-	-
Street	Enter the Street Name.	-	-	4000	String	-
City	Enter the city where the entity is registered.	-	Yes	1000	String	-
State	Enter the state which the entity is registered.	-	-	1000	String	-
ZIP	Enter the Country ZIP code.	-	-	100	String	-
Country	Enter the code of the country where the entity is registered.	-	Yes	1000	ISO2 Country Code	ISO2 country codes configured in the master data in the Oracle Financial Services Customer Screening Cloud application are accepted.
Phone	Enter the Phone Number.	-	-	100	String	-
Electronic Address	Enter the email, IP address or website address for the private watchlist records. Note:This field is used as a matching attribute for 314a screening .	-	Yes	4000	String	-
Electronic Address Type	Select the list of address types from the drop-down list to include information about email IP address and Websites. Note:This field is applicable for Individuals and Entities on the 314a Watchlist only.	-	-	512	String	The list of following values are accepted: Secure E-Mail Address Internet Protocol Address E-Mail Address Web Site Address IP Address
Tracking Number	Enter the Tracking Number. Note:This field is applicable for Individuals and Entities on the 314a Watchlist only.	Yes	-	4000	Alphanumeric	-