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Section 314(a) of the USA PATRIOT Act lets FinCEN ask financial institutions to search their records for named subjects of significant money laundering or terrorist financing investigations.

FinCEN publishes a subject list on a recurring basis. When you receive one, you are required to search your records for those subjects and report any matches back to FinCEN within the response window stated in the request. If you find nothing, there is nothing to report — but you are still expected to be able to show that you performed the search.

This tool performs that search against your own customer file and produces a dated PDF you can keep as your response record.

314(a) Search is a separate product, not part of Database Search. It is $29/month or $290/year, and you can buy it on its own or add it to any non-API plan at checkout.

If you see an upgrade prompt instead of the upload screen, your account is not licensed for it. Add it from checkout, or tick Add FinCEN 314(a) Search when changing your plan.

Buying 314(a) on its own does not include OFAC Database Search, and having Database Search does not include 314(a) — they are licensed independently. Team members on your account inherit whatever the main account holds.

FinCEN normally sends two files per request — one for individuals and one for businesses. Select both at once in Step 1. A single file containing both sections also works.

Upload the files exactly as FinCEN sends them. Do not open and re-save them in Excel first — that can reformat identifiers and dates and cause subjects to be read incorrectly.

Accepted: .txt (tab-delimited), .csv, .tsv, .xlsx, .xls.

Both files must go in together because a single tracking number routinely spans them — the same FinCEN case can list a person in one file and a related business in the other. Uploading them as two separate searches splits that case in half.

If you see "is not a FinCEN 314(a) file", the file is missing the expected 314(a) header row — check you selected the subject list itself and not a cover letter or transmittal.

Open FinCEN from the top navigation. The search runs in three steps:

• Step 1/3 — Select FinCEN 314(a) file(s). Drop in both files. Use View FinCEN Records to review the subjects that were read, grouped by tracking number, before you search.
• Step 2/3 — Select your customer file and map its columns (name, address, account number, phone, e-mail and so on). Only the columns you map are searched.
• Step 3/3 — Search. Progress shows Records, Searched, Matching Records and Subject Hits as it runs.

When it finishes you get a Search # and a results table, and the PDF is written to your local folder.

Matching Records counts your customer rows that matched at least one subject. Subject Hits counts every (customer row → subject) pair.

They differ when one customer row matches more than one subject — a single row matching three subjects is 1 matching record and 3 subject hits. Report by tracking number, so subject hits is usually the figure that matters when you respond to FinCEN.

314(a) matching is deliberately strict substring matching. It is not the fuzzy, thesaurus-expanded, scored matching used for OFAC screening, and there are no match scores here.

The rules:

• Every token of one of your mapped columns must appear in the same subject value. A name matches a subject name, not a subject name plus a separate alias.
• Aliases and DBAs are searched — they are held as additional values on the subject, so an AKA hit is a real hit.
• Names and identifiers are normalised on both sides first (upper-cased, accents transliterated, punctuation stripped), so O'Brien, Patrick and OBRIEN PATRICK match.
• Dates of birth, incorporation dates and addresses are never matched. They are carried through for display only, so you can eyeball whether a name hit is really your customer.

This is intentional. A 314(a) response is a factual "do these records exist in your institution" answer, so the search stays literal and auditable rather than probabilistic. Expect to review hits on common names by hand using the DOB and address shown.

Yes. Results are grouped by tracking number and value, so two distinct subjects who happen to share a name stay separate and each keeps its own tracking number.

That matters because your response to FinCEN is keyed on the tracking number — collapsing same-name subjects would under-report the case.

314(a) subject lists are confidential under 31 CFR 1010.520. You may not disclose them beyond what is necessary to perform the search.

The system is built around that:

• Subject names and your customer data are never written to any log.
• The subject list, your uploaded customer rows and the match detail are deleted from our database as soon as your PDF is written to your local folder.
• If you cancel a search part-way, the detail is purged immediately.
• After the purge, re-opening the results returns a notice that the detail is gone rather than the data.

The PDF you save locally is your record of record. Keep it with your 314(a) response file. If your PDF folder is not set, set it before searching — if the PDF cannot be written, the detail is deliberately not purged so you do not lose the result.

The job record survives so you can still prove the search happened: the Search #, the date, the file names, how many records were searched, the match counts, and which tracking numbers were covered.

What does not survive is the confidential content — subject names, your customer rows, and the match detail. 314(a) searches appear in your Search History.

314(a) Search has its own record limit, separate from the Database Search per-search limit. Large files are uploaded in chunks and searched in the background, so a large search survives a browser refresh — reopen the page and it will still be running.

If you exceed your limit you'll be told at upload time rather than part-way through the search. Contact support if you need it raised.

FinCENAnalyzer is operated by SanctionsAnalyzer, and account management is shared between the two. Your account page, password change, two-factor setup, team members and billing all live at sanctionsanalyzer.com.

Because the two sites are separate domains, you will be asked to sign in again when you get there. That is expected — it is the same account and the same password.

Browsers scope a sign-in to one domain. Signing in at fincenanalyzer.com does not carry across to sanctionsanalyzer.com, and vice versa. Your searches, history and licence are the same on both; only the sign-in is separate.

SSO sign-in is handled at sanctionsanalyzer.com. Sign in there first, then return here.

Email help@ofac.us or call 1-800-279-2302.