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#1193909 - 06/01/09 07:28 PM ADDRESS ON WIRE TRANSFER
Msunset Offline
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Msunset
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Posts: 145
We received a wire transfer where the originator included this information as address: "UID INSTEAD OF ADDRESS AS PER FATF LEGISLATION". Does anyone know if FAFT includes a section that overrules the travel rule?

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#1193922 - 06/01/09 07:36 PM Re: ADDRESS ON WIRE TRANSFER Msunset
Elwood P. Dowd Offline
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Elwood P. Dowd
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grin Well, I know enough about FATF to know they do not pass legislation. You could dig around the web site and try to make sense out of this or you could just call the bank who sent the wire and ask for a better explanation.

This is not a compliance issue for you. It's your job to keep the information you get; i.e. the transmittal order, not beat what they should have sent out of them.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1194114 - 06/02/09 12:13 AM Re: ADDRESS ON WIRE TRANSFER Elwood P. Dowd
MagicCity Offline

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They are referring to one of the 40 + 9 FATF Recommendations.

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#1194125 - 06/02/09 01:32 AM Re: ADDRESS ON WIRE TRANSFER MagicCity
Hrothgar Geiger Offline
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No, they're not. About 45 countries have passed banking legislation or regulations modeled after FATF Special Recommendation VII. These laws require that the originating party of a wire transfer supply full name, address and account number. There are provisions that allow for national ID numbers in lieu of an address.

To the original poster, BWPM, what was the country of the originating party.

And Ken's right under the US Travel rule your job is to maintain what was provided to you. (if you were in a country covered by a FATF SR VII-type law, though, your job would be to go after missing originator information.)

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#1194181 - 06/02/09 12:55 PM Re: ADDRESS ON WIRE TRANSFER Hrothgar Geiger
Msunset Offline
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Msunset
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We can not see for sure, since they did not include this information, the bank used was Merryl Lynch at Geneva

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#1194206 - 06/02/09 01:14 PM Re: ADDRESS ON WIRE TRANSFER Msunset
Hrothgar Geiger Offline
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Hrothgar Geiger
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Jersey Shore
In reverse order, Switzerland is not covered by the EU's passage of a FATF SR VII law, and it has not passed one of its own. So, it's anyone's guess why a Swiss bank would make reference to the standard.

Also, if the wire transfer used tag 50F for the originator information (instead of 50K), and if they truly did supply a national identity number, then you can tell the country of the originating party. Certain sub-tags within 50F require the presence of the 2-letter country ISO code to be present. And, the national ID number itself usually contains a country ISO code. For example, a Swiss national identity number starts with "756" which is the 3-digit ISO code for Switzerland.

If the wire troubles you, I would ask Merrill Lynch to supply the originating party information.

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