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#1217486 - 07/15/09 05:05 PM Bene Bank req Add'l Info on Foreign Wire- PossOFAC
summergirl Offline
Member
Joined: Jul 2009
Posts: 52
Delaware
We have a customer whose name matches an OFAC name--other info-DOB, ID, Address, name variation is not a match. The customer executed outgoing Int'l wire transfer and the beneficary bank ia asking for place of birth, national ID# & DOB of our customer. For our CIP we have SS#, DOB, DL#--Can we share this info? Are we required to contact our customer for place of birth and other requested information?

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#1217498 - 07/15/09 05:13 PM Re: Bene Bank req Add'l Info on Foreign Wire- PossOFAC summergirl
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
The driver's license number will mean next to nothing to a foreign bene bank. It's likely that you will have to contact your customer for their place of birth, unless you alredy have that.

For what it's worth, from the scenario you described, I would guess that the bene bank is asking for this data because the wire transfer lacked full originating party name, address and account number. The data they've asked for is consistent with the data required under EC 1781/2006.

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#1217635 - 07/15/09 06:59 PM Re: Bene Bank req Add'l Info on Foreign Wire- PossOFAC Hrothgar Geiger
summergirl Offline
Member
Joined: Jul 2009
Posts: 52
Delaware
We did provide the originating parties name, address, & acct# as well as went back and provided them with the DOB etc. The customer is of foreign decent however we don't seem to have on record exactly where he is from. As you stated at this point we will have to reach out to the customer to obtain but since this was never a request recieved wondered what our obligation to the foreign bank is & if anyone had the same issue previously.

Thanks for your help!

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#1217672 - 07/15/09 07:29 PM Re: Bene Bank req Add'l Info on Foreign Wire- PossOFAC summergirl
Blessed Offline
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Blessed
Joined: Oct 2007
Posts: 2,390
USA
Could you request documentaction from the Bene Bank as to why they are requesting this information and why they feel itis your obligation to provide it?
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#1217714 - 07/15/09 07:50 PM Re: Bene Bank req Add'l Info on Foreign Wire- PossOFAC summergirl
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
As a practical matter, all you can do is go back to the originator, ask for the information, and request permission to provide it to the beneficiary bank. Otherwise it appears they are either going to return the wire or, worse yet, block it.
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