I was hoping that someone could provide clarification regarding the travel rule requirements for obtaining beneficiary address, specifically the zip code. In the case where all beneficiary address information traveled with the wire except the beneficiary zip code in your opinion would this be considered a travel rule violation?

The intent of the travel rule is to provide enough information so the beneficiary could be identified by law enforcement or could be used to clear a potential OFAC match. I think if the rest of the address outside of the zip code traveled that would meet those requirements regardless of whether the zip code was gathered from the customer.

As many of the following items as are received with the payment order:

(1) The name and address of the beneficiary;

If you don't get it with the payment order, you don't get it. If you get it, it has to be included.

The travel rule calls for a bank to retain and pass along the beneficiary address if it receives that information, not that it be obtained. As to the question of clearing an OFAC match, a ZIP Code could be helpful, particularly if the address in question is a post office address rather than a physical address, and there are multiple post offices within a city.

John, I think the OP is saying they gather the beneficiary's zip code from the originator, but do not forward it within the wire order.

Yes, in some instances we gathered the beneficary address (including zip code) however only sent the street address, city and state and not the zip code. I understand the travel rule states to send as much information as we have however what exactly the address includes is not clear in the regulation or in the FFIEC Manual. I'm not sure it should be considered a violation if we sent everything but zip code. Between name, and the remaining pieces of the address I think that would be sufficient information for law enforcement to identity the beneficiary.

So what you are saying is that the originator provides you a beneficiary's address including zip code and the bank does not consider the zip code as part of the "As many of the following items as are received with the payment order".

Interesting argument, but not one I would want to try and make with a regulator.

I have to agree with Randy. The ZIP Code is part of the U.S. address, just as much as a postal code is part of a Canadian, UK or other address. I think it's likely to be considered a technical, rather than substantive, violation, but even technical violations can be problematic if there are any other cracks in your BSA/AML compliance program.

Thank you both for your responses.

If you got the information, you must send the information with no editing or redaction.