I need to make sure I understand. On outgoing wire transfers do we need to check the name of the beneficiary and on incoming do we need to check the name of the originator.

We got examined and they cited us for lack of 314a searches on beneficiaries of outgoing wires and originators of incoming wires. We argued with them and they backed down. So, I guess the real answer is, "No, it is not required, but you may have to argue."

Also, be sure you do an OFAC search on ALL parties to wire transfers. (They even indicated that we should search the intermediary bank! We refused on common sense grounds unless it was a foreign bank.)

Wish me luck and include me in your prayers. Our case manager told me the OCC BSA exam team will be at our bank for a targeted BSA exam on January 10th.

Our USA PATRIOT exam was never finalized. The letter from the OCC said something about a "resource challenge" and said that the exam would be concluded sometime in the first quarter.

The case manager told me that the OCC is conducting a "Horizontal review" of BSA throughout the banks. "Horizontal?" I asked....and he said that the BSA exam is simply a straight line going through the banks and it is not being combined with the Safety and Soundness exam this time.

Y'know what stresses me about this? (Besides the obvious - what if they feel we aren't doing a good enough job.... - The exam entry letter with it's huge list of stuff to compile and submit will be coming just in time for the holidays.

So...instead of doing ACTUAL WORK, we get to spend hours putting together nice binders of stuff.

Could I get a copy of that 314 (A) policy or procedure? Thanks a lot - my email is matt@capitalcombank.com if you could send it as an attachment

We are being examined right now, and are being cited for not checking 314(a) on wires....is there any reasoning that I can use in arguing the citation?

If you do not do wires (in or out) for non-account customers you do not need to check wires separately vis-a-vis 314a since this will be checked when you check your CIF. Hope this helps. If you do wires for non-account customers, you need to check.

Can't argue not checking non-acct wire transfers. They have to be checked. Nothing you can do but draft up a policy/procedure for checking 314a requests against your non-acct wires, and wait for that good'ol examination train to rool around.

Matt, I PM'd you...

must have email address, must have email address...