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#318822 - 02/18/05 10:41 PM 314(a) Attorneys Trust Accounts
Anonymous
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We only handle wires for our own customers. This helps a lot with the 314(a) requests. A large portion of our incoming wires are to real estate closing attorneys (our customers) for the benefit of a buyer (NOT our customer).

I read the FinCEN instructions to include benficiary/recipient....so is the Attorney a recipient and the non-customer a beneficiary? And do we therefore need to check the attorneys clients' names against the 314(a)?

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#318823 - 02/21/05 05:48 PM Re: 314(a) Attorneys Trust Accounts
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We check all names that are put on the wire instructions. Our Real Estate attorneys sometimes have a file number on the transaction and some put surnames. If we get an OFAC hit on the surname, we call our customer for full details on their customer to determine if it is a true hit. So in answer to your question, if you have knowledge of the clients name you should check it.
Hope this helps.

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