FinCEN 314(a) Request Run Through an HSI Los Angeles Task Force Lists 29 Subjects; the SEIU Return in the Same Exhibits Held No Records

Three Sant exhibits, read together, show a FinCEN 314(a) request run through an HSI Los Angeles task force for a case the defense ties to the Minnesota investigation, and show that the SEIU document WIRED described is a “no records” return, not a batch of records.

The request. Exhibit 52 (Doc. 249, filed August 27, 2026) is a table titled “Law Enforcement Information Sharing with the Financial Industry”, with columns for transmission date, tracking number and number of subjects. Under the March 31, 2026 transmission date, the row for tracking number SCM-16112-T2X2J lists 29 subjects. (A second row in that group, SCM-16050-K7C5G, also lists 29, so the figure alone does not identify the case.) The page does not say “314(a)”, whose request it is, or what investigation it belongs to. Exhibit 50 (Doc. 244, filed August 26) supplies the link: the same case number SCM-16112-T2X2J heads a FinCEN email sent Wednesday, April 1, 2026, at 8:15 PM saying FinCEN “has received a positive response to your 314(a) request from one or more financial institutions.” A supervisory special agent in HSI Los Angeles’s “Cyber Financial | HSI Los Angeles HSTF 4” unit forwarded it on April 2 to the agent who wrote the Whipple Shield reports in Doc. 231-2 and Doc. 231-3. Later emails in the chain, on April 3, 8, 10 and 21, ask for and attach further 314(a) responses and a FedWire response. Nothing in the exhibits names the Minnesota case on its face.

What the defense says. The September 25 defense response (Doc. 271) states that the Los Angeles agent “investigated twenty-nine different individuals and/or organizations in connection with Operation Puppet Master, using Section 314(a) of the Patriot Act” and asks for the certifications 31 C.F.R. 1010.520(b)(1) requires. That is the defense’s characterization. No government answer on the point is among the documents held.

The SEIU document. Exhibit 51 (Doc. 244-1) is a June 10, 2026 email from an HSI St. Paul special agent to two colleagues, “For filing wherever the results are being stored,” forwarding a reply to Grand Jury Subpoena #2026R00210-0025. The reply, from SEI Private Trust Company, says its “314(a) match” does not reflect “any current or historical account relationship” with SEIU; the match rested on historical payee information in a third-party client’s closed accounts; and the company “has no records of transactions, payments, or other responsive account activity involving SEIU.” WIRED wrote that batches of records were turned over under the 314(a) inquiries, “including some dealing with SEIU.” The exhibit shows a grand jury subpoena and a return that held no SEIU records.

What is not shown. The 29 subjects are not named in any exhibit held. Whether the other financial institutions’ responses held records is not shown. The exhibits do not show who certified the request or on what stated basis.

Sourcing note. Exhibits 50 and 51 are image-only scans and Exhibit 52’s table columns do not survive text extraction, so this entry carries no machine-checked claims (verification: captured). The row match for SCM-16112-T2X2J was read from a layout-preserved extraction and the page image; quotations were read from the page images.