By Meghan Sutherland – CEO, FiVerity
Last month, the Treasury's Financial Crimes Enforcement Network published its first substantive rewrite of the Section 314(b) fact sheet in nearly six years. Treasury tied the release to a broader anti-fraud effort, citing an estimated figure of hundreds of billions of dollars lost to fraud each year, well beyond what any single institution can address alone.
The update tells financial institutions, plainly, that they may share fraud information with one another under a legal safe harbor without first constructing a money-laundering theory to justify doing so. For most of the industry, this is a clarification. For FiVerity, it's validation. FiVerity's joint-investigation and secure-messaging tools were built well before this guidance was published, so the update doesn't change FiVerity's course. It simply supplies the government's own language for a course already set.
The fact sheet confirms that a non-bank "compliance services provider" may form and operate a 314(b) association. FiVerity has been a registered FinCEN 314(b) association for years. The update also removes the old requirement that a sharing request be tied to identified laundering proceeds. Fraud alone now suffices, which matches how the great majority of FiVerity's alerts already originate in practice: as typology hits, not as laundering hypotheses assembled after the fact. And the expanded list of shareable data, including IP, geolocation, a newly added payee followed swiftly by a large transfer, and multiple accounts sharing identifying details, reads less like new policy and more like a description of FiVerity's existing signal set.
Because FiVerity is itself the registered association, its non-customers are not on the outside of this looking in. They inherit the safe harbor and the network the moment they join, and they leverage it through the same identity intelligence FiVerity already runs at its core. A suspicious entity that a financial institution investigates through FiVerity’s joint-investigation workflow is evaluated for risk by assigning fraud typologies and behavioral signals, which are returned as a clickable identity summary inside the 314(b) secured communication thread. That means a participating organization can quickly reason about the subject and provide context back to the requesting institution with the full weight of cross-institution intelligence behind the request.
There is a further point here that ought to interest anyone thinking about this from a compliance seat. Unlike other platforms that rely on personally identifiable information (PII) to identify potential matches, FiVerity uses PII to enrich fraud signals rather than generate them. Investigators begin with behavioral and transactional indicators, using PII to provide additional context that strengthens and validates those signals.
A case investigator first works the signals derived from that data, phone, email, IP, geolocation, and typology before any PII is exposed in the UI. PII is only displayed and shared once a 314(b) request is initiated, which means the basis for a 314(b) request is genuinely unbiased. The institution is acting on a pattern of fraud, not on who a person appears to be. That precedence matters. A request grounded in signal rather than identity gives an institution a defensible, documented reason to share, and it avoids the quiet risk that PII-first screening can carry, unintentionally redlining individuals rather than pursuing fraud. Fewer institutions talk about it, but leading with signal rather than identity is one of the stronger compliance arguments for how FiVerity works.
FiVerity’s mission rests on a simple premise: fraud doesn’t respect the boundary between one institution’s ledger and the next. Fraudsters coordinate across banks and credit unions, so the institutions defending against them need to share intelligence just as freely, and just as securely. The software built to fight fraud should make that collaboration safe rather than leave each institution to face the problem alone. A community bank in Massachusetts and a credit union two states north can be staring at the same synthetic identity ring without either knowing the other exists. Collaboration, not another dashboard, is the multiplier, the connective tissue between institutions that would otherwise be investigating in the dark.