314(b) consortium screening for inter-bank financial-crimes signals
The 314(b) Cross-Bank Financial Crimes Watch List is a cross-bank shared
consortium that extends beyond one sponsor-bank network and focuses on sharing
suspicious financial-crimes activity. It is governed by banks as defined by
31 CFR 1020.100(d), under 314(b) permissible purpose. It answers — is this
consumer associated with suspicious financial-crimes activity reported across
participating banks? — returning a listing indicator plus a small set of
context fields. It never issues a reusable certificate.
Category
Fraud & Financial Crime
Use case
Watch list screening
Subject
Consumer
Family
List (query-only)
Scope
All participating banks — visibility spans the consortium
Operation
POST /v1/products/cross_bank_financial_crimes_watch_list/query
Unlike the Bank-Specific Bad Actor List,
this list is cross-bank by design: it exists so that suspicious financial-crimes
activity observed at one bank is visible to the others, under the 314(b)
information-sharing framework. The events behind it are contributed by network
participants through governed furnishing flows.
A clean result is "is_listed": false (always 200 OK, never 204). When the
consumer is listed, the context fields — including a placement date and the
entity_level_adverse_action_eligible_indicator — are populated.
Subjects are matched on the consumer identity behind your
consent record. SSN and date of birth are
mandatory match inputs; name, phone, and email refine the match.Event categories include money_laundering, terrorist_financing, and fraud;
signal levels are high, medium, or low. A network’s
querying policy can restrict which
categories and signal levels a query considers — for example, only high-signal
events.
Field
API name
Type
Event Date
event_date
Date
Event Category
event_category
String
Signal Level
signal_level
String
Watch-list signals are screening inputs, not adjudications. Whether a listing
can support adverse action depends on your program’s compliance framework —
this list operates under 314(b) permissible purpose, and the
entity_level_adverse_action_eligible_indicator exists precisely because not
every signal qualifies. Route hits to your compliance review process.
Full field reference & matching rules
The screening lists deep dive — match inputs, per-list event fields, and
compliance posture.