What community banks & credit unions can share about fraud under 314(b)

This page is for a BSA officer, a fraud manager, or anyone in compliance at a community bank or credit union who has been asked a practical question: can we share fraud information with another institution under 314(b), what exactly, and which tools produce the data we would send? The short version is yes, when you are registered and you follow the conditions. FinCEN's June 12, 2026 fact sheet ↗ is the document to read. This page maps that sheet, the later 2026 statements, and the OCC reporting tool onto the fraud and BSA listings already on BankToolkit.

Listings are informational only. BankToolkit does not endorse, rank, or score products. Account takeover and other payment rails are in the fraud prevention guide. Inbound mule activity is in the money mule guide. Check images, positive pay, and kiting are in the check fraud guide.

314(b) in one paragraph

Section 314(b) of the USA PATRIOT Act ↗ is voluntary. It lets a financial institution share information with another participating institution, under a safe harbor from liability, in order to identify and, where appropriate, report activity that may involve money laundering or terrorist activity. FinCEN’s page says that activity may include fraud and other specified unlawful activity. The June 12, 2026 fact sheet says the same thing in more detail, and it says you do not have to name specific proceeds of fraud before the safe harbor can apply. The safe harbor is for the sharing, and for not notifying the person you named that you shared: that is the wording in 31 C.F.R. 1010.540(b)(5) ↗, which points to section 314(b) of Public Law 107-56 for how far the protection goes. It does not apply if you skip registration, skip a reasonable check that the other institution is registered, or skip the rules on how the information may be used and protected.

What changed in 2026

Checked November 2, 2026 (America/Los_Angeles). Dates below are the dates on the documents, not a rank of importance.

ProSight’s October 26, 2026 explainer ↗ also cites its summer 2026 State of Fraud Prevention Survey. These are the only survey figures this page uses: 72% of respondents said they share or report notable fraud incidents to law enforcement, 24% share informally with peers, and 20% share through formal networks or platforms. 91% expressed interest in deeper collaboration and information sharing among financial institutions, including 64% who were very interested.

What you can share, and what you can’t

The left column is FinCEN’s own examples from the June 12, 2026 fact sheet, paraphrased. The right column is the limit the same sheet repeats: you may share facts that led to a SAR, or that might lead to one, and you may not share the SAR itself or reveal whether one exists.

Two limits sit next to that table, not inside it. First, institutions that share under 314(b) and are considering or have filed a joint SAR may discuss that joint SAR among themselves. That exception is in the fact sheet. It is not permission to forward a SAR to an institution that is not part of the joint filing. Second, the September 2, 2026 joint statement says the underlying facts, transactions, and documents are not themselves the SAR. You can discuss those facts with a customer or with another bank or credit union. You still cannot reveal that a SAR exists.

The fact sheet lists who may participate. The list includes banks, at 31 C.F.R. 1020.540. 31 C.F.R. 1010.100(d) ↗ defines bank to include a credit union organized under the law of any State or of the United States. If your charter is unusual, confirm eligibility with counsel before you rely on the safe harbor.

Before you share: the checklist

The first four items are the conditions in the fact sheet and in 31 C.F.R. 1010.540. The fifth is a desk record. The fact sheet does not call it a log, and this page does not invent a FinCEN form. Not legal advice. Confirm the list with counsel against your own policy.

1. Register with FinCEN. The fact sheet tells you to request access to the Financial Industry Portal (FI Portal) from FinCEN’s financial institutions page ↗, then submit the 314(b) registration in the portal. FinCEN’s 314(b) page ↗ points you to those instructions. Registrations are processed automatically, and you can generate an acknowledgment letter. Update the registration in the portal when a contact changes. The fact sheet and the 314(b) page we opened do not state an annual renewal date.
2. Verify the other institution is registered. Take reasonable steps before you share. The fact sheet points to a searchable directory of participants in the portal. The regulation also allows you to confirm directly with the other institution that it has filed the notice.
3. Protect what you share. Keep procedures that safeguard the security and confidentiality of 314(b) information. The regulation says those procedures are satisfied to the extent you apply the same protections you already use for customer nonpublic personal information under section 501 of the Gramm-Leach-Bliley Act.
4. Limit the use. The fact sheet and the regulation allow three uses: identifying and, where appropriate, reporting on money laundering or terrorist activity (the fact sheet includes fraud and other specified unlawful activity); deciding whether to establish or maintain an account, or to engage in a transaction; and assisting with anti-money-laundering requirements. Both the sender and the receiver need the safeguards.
5. Write down the share. For your own exam file, record who you checked, when, what you sent, and which permitted use it fit. That note is a practice on this page. It is not a quoted FinCEN requirement. Do not paste a SAR, or a sentence that says whether a SAR exists, into the note you might later show outside the SAR file.

The safe harbor regulation covers the sharing and a failure to tell the person you named that you shared. It does not mention a later hold, a closure, or a customer notice. In the answer about sharing onward with a foreign institution, the fact sheet says other U.S. laws, including the Right to Financial Privacy Act, the Gramm-Leach-Bliley Act, and state law, sit outside that guidance. Treat the next action as its own decision. Confirm it with counsel.

The OCC reporting tool

This is a report to the OCC. It is not 314(b), and it is not a feature this page assigns to any software vendor.

OCC news release 2026-86 ↗, dated October 7, 2026, says Comptroller Jonathan Gould announced a tool for community bankers to report suspected payments fraud involving OCC-regulated institutions directly to an OCC fraud task force. In remarks the same week (PDF) ↗, dated October 6, 2026, Gould says the OCC is rolling out a tool for community bankers to notify the OCC of suspected payments fraud in real time. The release, in a separate sentence, points banks to the OCC bulletin on FinCEN’s 314(b) guidance for information sharing across institutions.

American Banker, October 7, 2026 ↗, reports the same announcement and writes that information will be shared across institutions. Read next to the OCC release, the cross-institution sharing the release names is 314(b). This page does not treat the task-force report and 314(b) as one pipe.

The release limits the report to suspected payments fraud involving OCC-regulated institutions. A credit union is usually supervised by the NCUA, not the OCC. Do not assume the tool is open to your charter. Ask counsel. This page did not find a public BankToolkit vendor page that says the product connects to the OCC tool, and it does not claim that any listing does.

Tools that help

Software does not register you, and it does not verify the other institution. Those two steps stay with FinCEN. What the listings can do is produce the underlying facts you might then share, if counsel agrees: a device identification number, a monitoring alert, or an account decision. The path is register, verify the counterparty, share the fact, then decide only for a permitted use.

This is a map, not a ranking. Nothing in the table says a product meets the 314(b) rules, and nothing in the table says a product connects to the OCC tool. Confirm, in a demo, that you can export the fact without exporting a SAR.

Some of those vendors describe consortium or network data on their own public pages. This guide does not repeat those claims, and it does not treat a consortium as 314(b) registration. The money mule guide’s consortium section records which public pages say that, and what to ask before you rely on them. Check images and deposit decisions are in the check fraud guide, not in the table above.

ComplyAdvantage is listed on BSA / AML for screening and monitoring. This page does not put it in a sharing lane. Ask whether a screening hit is a fact you are allowed to send.

Related guides

• Money mule detection: red flags, and the consortium lane for what other institutions already saw.
• Fraud prevention software: account takeover, payments, and new-account signals.
• Check fraud detection: image analysis, positive pay, and kiting.
• Fraud Prevention and BSA / AML.
• Vendor pages named above: BioCatch, ThreatMark, Sardine, Feedzai, Featurespace, Hawk, Abrigo, Verafin, NICE Actimize, Alloy, Unit21, ComplyAdvantage.
• Submit or claim a listing, BankToolkit Weekly, all guides.

What we still cannot cite

• An annual renewal date. The June 12, 2026 fact sheet and the FinCEN 314(b) page tell you to register and to update the registration. They do not state a yearly cycle.
• A FinCEN form called a log. The written note in the checklist is a desk practice.
• A sentence that the safe harbor allows or forbids a later hold or closure. The regulation we opened covers the sharing and a failure to notify. The fact sheet, in its foreign-institution answer, places the Right to Financial Privacy Act, the Gramm-Leach-Bliley Act, and state law outside the guidance.
• The statutory phrase that spells the safe harbor out as federal and state liability. The current regulation says you are protected from liability for the sharing, to the full extent of section 314(b) of Public Law 107-56. This page does not restate words it did not open in the statute.
• A public vendor sentence that says a product participates in 314(b) or connects to the OCC tool. This page does not make that claim.
• Prices, ranks, detection rates, and consortium sizes.

Quick answers

What is 314(b)?

Section 314(b) of the USA PATRIOT Act is voluntary. It lets a financial institution share information with another participating institution under a safe harbor from liability, so they can identify and, where appropriate, report possible money laundering or terrorist activity. FinCEN’s 314(b) page and the June 12, 2026 fact sheet say that can include fraud and other specified unlawful activity. This is not legal advice. Confirm with counsel before you share.

Can a community bank or credit union share fraud information under 314(b)?

Yes, if you are eligible, you register, and you meet the conditions. The June 12, 2026 fact sheet says you do not have to have identified specific proceeds of fraud being laundered. The fact sheet lists banks among eligible institutions. A credit union organized under state or federal law is a bank under 31 C.F.R. 1010.100(d). Sharing is still voluntary. Confirm eligibility, and the particular share, with counsel.

What can we share, and what can’t we share?

You can share the underlying facts: transaction information, cyber data such as IP addresses, geolocations, and device identification numbers, monitoring alerts, account decisions, attempted transactions, and activity that never became a transaction, including attempts to recruit a money mule. You can share in real time, and even when the information is not about the other institution’s customer. You cannot share a SAR or reveal whether a SAR exists. Institutions working on a joint SAR may discuss that joint SAR among themselves. The September 2, 2026 joint statement says you may discuss the underlying facts with a customer or another bank or credit union if you do not reveal that a SAR exists.

What changed in June 2026?

On June 12, 2026, FinCEN replaced its 2020 fact sheet and made explicit that suspected fraud can be shared under 314(b) without first identifying specific proceeds. On July 9, 2026, the OCC and the FDIC each told institutions about that guidance. On September 2, 2026, FinCEN and four agencies said SAR confidentiality does not bar a discussion of the underlying facts. In October 2026, Comptroller Jonathan Gould announced an OCC tool for community bankers to report suspected payments fraud involving OCC-regulated institutions to an OCC fraud task force.

What is the OCC fraud reporting tool?

The OCC’s October 7, 2026 news release says Comptroller Jonathan Gould announced a tool for community bankers to report suspected payments fraud involving OCC-regulated institutions directly to an OCC fraud task force. His October 6 remarks say the tool lets community bankers notify the OCC of suspected payments fraud in real time. American Banker reported on October 7, 2026 that information would be shared across institutions. The OCC release describes the report to the task force, and it points to 314(b) for sharing among institutions. This page does not treat those as the same channel. Most credit unions are not OCC-supervised. Confirm with counsel whether the tool applies to your charter. This is not legal advice.