BSA examiner is going to comment that an outgoing wire instruction form contained a POBox for the beneficiary's address and that an income wire instruction form had a POBox for the sender's address, neither of which party is our customer! The examiner is telling us that we have to follow CIP because law enforcement won't know where to find those parties if the street address is not on the form. The "C" is for customer; the beneficiary and the sender on these wires are not our customers. The exam manual explains that a street address is not required under this rule. Am I missing something??

CIP applies to non customer information on wires? That's pathetic.

On outgoing wire transfers, you are not required to obtain the recipient's address. If you do obtain it, however, then you are required to keep it and it must travel with the wire. If you were not required to get an address at all, no one can say you were required to get a physical address. (The wire transfer record retention requirements pre date CIP by several years and they do not stipulate that any address has to be a physical address.)

On incoming wire transfers all you have to keep is the information you received. If the originating bank failed to send required information you are not required to reject the wire or beat the information out of them.

Call the Helpline to garner a supporting resource. Reference that phone call and the exam manual when you tell the examiner that the criticism is incorrect. If the criticism surfaces in the exit conference, reiterate your response and call the ombudsman while the examiners are still walking toward your parking lot.

Amen to all that Ken has said.

This is definitely not an item that you should let the examiner slide on. It may seem inconsequential, but it is a "camel's nose under the tent flap" from which no good can come. It's also a lesson the examiner will have to learn sooner or later -- don't confuse the requirements of separate rules. He or she may not think so, but you'll be doing him or her a favor by sticking to your guns on this problem.

Thanks for your support! I referred the examiner to the page in the exam manual that refers to addresses and pointed out, as you say, that this rule is different than CIP. She is looking into it further. Good to know I haven't lost my mind, yet. After 30 years of being in compliance, I think it won't be long, though...

Funny, having this same discussion with an examiner this morning. Wonder if its the same person - or they attended the same examiner training session for "low hanging" travel rule issues.

Do you think the Examiner is confusing the travel rule for funds transfer with the Swift message requirements for cross border transfers. I had to complete a BSA/AML correspondent bank questionnaire recently, and one of the questions had to do with the SWIFT message information. I had to do some research in order to answer this question.