As I understand 314(a) regs we are required to search all Funds Transfers for transmitters and receipient matches. We still do wire transfers manually by calling a correspondent bank. We keep all of our requests on paper. Is there an exemption from searching if we are not maintaining records electronically?

I believe if it is a manual system, you have to go back 6 months. That is what we are doing.

You need to search on originator name on outgoing wire transfers and on beneficiary name on incoming wire transfers. If you do not do wire transfers for non-account holders, you need not search any wires against the 314a lists since the searches will be covered when you search against your CIF. Hope this makes sense.

Hey Devil Queen: Are you searching both originator and beneficiary on wires out and vice versa for wires in?

From the 314(a) Q & A's:

On who do we search for on wires:

5. What records should a financial institution search?

Unless noted otherwise in the instructions to a 314(a) request, a financial institution is required to conduct a one-time search of the following records, whether or not they are kept electronically (subject to the limitations below):

(1) [abridged]

(2) funds transfer records maintained pursuant to 31 CFR 103.33 to determine whether a named subject was an originator/transmittor of a funds transfer for which you were the originator/transmittor’s financial institution, or a beneficiary/recipient of a funds transfer for which you were the beneficiary/recipient’s financial institution;

On manual searches in general:

7. Does a financial institution need to conduct a manual search of its records?

Unless noted otherwise in the instructions to a 314(a) request, and subject to the following exceptions, financial institutions are required to search all the records described in Q&A #5 whether they are maintained electronically or not. First, safe deposit records are only required to be searched if they are searchable electronically. Second, any record described in Q&A #5 not maintained in electronic form need only be searched if it is required to be kept under federal law or regulation.