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.

The short and sweet of it is - your auditor is right about needing to provide your customer's account number in the wire record.

In addition, if the wire transfer is going outside the US, chances are good (based on the number of countries that have passed laws stronger than the Travel Rule in the last 2 years) that the receiving institution will require you to provide that information if it is missing. They may even charge you additional fees for handling the payment if it lacks the required information.

The significance? Governments have determined that law enforcement's need to be able to trace money flows for AML purposes trumps privacy concerns.

Thank you all for your helpful insight! Luckily, our mid-western thrift doesn't permit international wire transfers.

John, your response especially answered our privacy questions. Much appreciated!

No more so than when a check written by your customer is deposited to another bank.