I am new to BOL (and to Compliance) so please be gentle.
During a recent compliance audit, our internal auditor noted that we do not follow BSA's Travel Rule requirement because we don't include our customer's account number on outgoing wire transfer transmittals. We've been audited by the same company for 14 years and this is the first time this has been noted as a finding. They sited the following:
"Travel Rule Requirement
For funds transmittals of $3,000 or more, the transmittor’s financial institution must include the following information in the transmittal order at the time that a transmittal order is sent to a receiving financial institution (31 CFR 103.33(g)(1)):
Name of the transmittor, and, if the payment is ordered from an account, the account number of the transmittor."
My question is this: Isn't it a privacy concern to provide our customer's account number to another FI, especially since it isn't necessary for them to perform the transfer? Please help me understand.
Last edited by Treading Water; 04/22/09 06:18 PM.
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