Unlocking Real-Time Collaboration: FinCEN’s Historic 314B Fraud Guidance Update

In this episode of Fraudology, Karisse Hendrick sits down with Hailey Windham, Community Lead for Banking at Sardine and host of the Fraud Forward podcast. Hailey shares her journey transitioning from a practitioner at community financial institutions to the vendor side, focusing entirely on providing practical, operational insights for credit unions and community bank fraud teams.

The conversation explores the highly anticipated June 2026 updated guidance from FinCEN regarding Section 314B of the USA Patriot Act. Hailey breaks down how this new fact sheet eliminates long-standing confusion and regulatory fears, giving financial institutions a robust legal framework to safely share information and collaborate under a liability safe harbor.

We also explore the "hot topics" dominating the banking fraud landscape today:

• Fraud Explicitly in Scope: How the new guidance expands past narrow money laundering limits to formally include computer fraud and scams targeting individuals, organizations, or governments.
• Reasonable Suspicion vs. Certainty: Why teams no longer need a fully completed investigation or total certainty before sharing data, making early sharing on incomplete information permissible.
• Real-Time Data Transmission: The protocol shifts allowing financial institutions to share verbal alerts, video surveillance footage, IP addresses, and attempted transactions in real time.
• The Power of Associations: How non-bank compliance providers and industry trade groups can now legally organize 314B associations so smaller institutions don't have to fight fraud alone.

Additionally, Hailey dives into the preliminary insights from the industry’s first practitioner-built benchmarking survey for community banks and credit unions under $10 billion. We examine the systemic issues keeping banking fraud fighters up at night, from rigid legacy core system limitations to the immense pressures of tackling an exponential surge in social engineering scams with limited resources.

Connect with Hailey Windham