Based on the travel rule requirements, are we obligated to return a wire transfer if for the beneficiary information fields (which would be our customer)it only comes through with the beneficiary name and not an address? Since we would know what the beneficiary address is (being that our customer is the person/business receiving the funds) are we still required to return the funds or can we get away with posting the funds since we house our customers full information.

The originating bank is only required to send the beneficiary's address if they receive it. You have no way of knowing whether they received it or not.

Regardless, you are the receiving or beneficiary bank. Your only responsibility is to keep the information you receive; you do not serve as a pseudo regulatory agency that assures the originating bank's compliance with the travel rule. Returning a wire solely because it is missing information required by the travel rule could put your bank in a world of hurt with your customer.

FIN-2010-G004 reflects FinCEN's most recent guidance on the travel rule.