2020-12-10
The Financial Crimes Enforcement Network rescinded administrative ruling FIN-2012-R006 regarding an association of financial institutions' participation in the Section 314(b) information sharing program. This action was taken to align with updated guidance in the December 2020 Fact Sheet, although the underlying determination that the entity met technical requirements for safe harbor protection remains valid. The rescission addresses advisory aspects of the prior ruling rather than overturning the factual conclusions about the entity's eligibility.