Flggd
White paper · October 2026
The permission without the evidence
What FinCEN's June 2026 section 314(b) guidance changes for fraud, and what it still leaves unsolved.
Written for fraud, financial crimes and compliance leaders. About fifteen minutes to read.
asset
314b-paper
01
What the guidance says Fraud is in scope, and sharing can be live.
02
The gap it leaves The best evidence exists before the payment.
03
The layer that is missing Consumer-sourced, pre-transaction, timely.
Figure 1. The asymmetry that section 314(b) does not resolve. The institution's first sight of the scam is the payment instruction, by which point the money is moving.
DAY 0 THEN HOURS OR WEEKS BEFORE THE PAYMENT PAYMENT DAY The first message A reply Trust, then pressure Coaching The payment WHAT THE CUSTOMER HAS A text or call A friendly reply Mounting urgency Told what to say A transfer they believe in WHAT THE INSTITUTION SEES Nothing Nothing Nothing Nothing An authorized payment The gap: everything that happens before the payment
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