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CAFP: Financial Intelligence, Investigations, and Information Sharing

CAFP · Work through your exam, one topic at a time.

All guide sections

Financial Intelligence, Investigations, and Information Sharing

What the exam tests

This domain tests the intelligence cycle, FIU roles, investigative techniques and lawful information sharing. Expect questions on FinCEN, the Egmont Group, Section 314(a)/(b) and cross-border sharing.

Core rules and concepts

  • Financial intelligence is produced through collection (SARs/STRs, CTRs, reports), analysis (patterns, links, typologies) and dissemination (to law enforcement, regulators, foreign FIUs). An FIU receives and analyses reports; FinCEN is the US FIU. The Egmont Group facilitates FIU cooperation.
  • Investigations may use link analysis, transaction tracing, open-source research, interviews and subpoenas. Investigators must preserve evidence and document hypotheses.
  • US PATRIOT Act Section 314(a) allows law enforcement, through FinCEN, to request that financial institutions search records for specified individuals or entities. Section 314(b) allows financial institutions to share information with each other for AML/CFT purposes, subject to registration and safe-harbour conditions.
  • Cross-border sharing may occur through FIUs, MLATs, supervisory channels and, where permitted, institution-to-institution arrangements. Data protection and tipping-off laws can limit disclosure.
  • SAR confidentiality persists; sharing under 314(b) does not permit tipping off the customer.

Worked example

FinCEN issues a 314(a) request naming a customer. The bank searches its records and finds an account and two wire transfers. It reports the match to FinCEN within the required timeframe. Separately, the bank wants to share the case with another bank that has related transactions. It may use 314(b) only if both institutions are registered and the sharing meets the safe-harbour conditions. Reasoning: 314(a) is a law-enforcement request to search; 314(b) is a voluntary institution-to-institution sharing channel with legal protections.

Traps that cost marks

Do not confuse 314(a) with 314(b). Do not share SARs with other institutions outside the safe harbour. Do not ignore foreign data-protection restrictions. Do not assume an FIU request is a subpoena; follow the specific legal process. Do not fail to document the search and response.