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A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of...

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A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of a customer's account activity. The customer is part of an ongoing investigation into a money laundering operation. At the same time, the institution has received a FinCEN 314(b) information-sharing request from another bank seeking details on transactions linked to the same customer. The compliance team is tasked with responding to both the subpoena and the FinCEN 314(b) request.

What should the compliance officer prioritize in responding to these requests while ensuring that all legal and regulatory obligations are met?

A.

Notify the customer of the information-sharing request from the other financial institution and seek their consent before responding

B.

Consult the institution's legal counsel to validate the subpoena, then respond directly to law enforcement while ensuring all documentation is properly recorded

C.

Respond to the FinCEN 314(b) request first, as it allows for voluntary information sharing with partner organizations

D.

Provide the requested records to both law enforcement and the other financial institution immediately to ensure full cooperation and transparency

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