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#343930 - 04/07/05 02:52 PM Travel Rule
Rosebud123 Offline
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Joined: Oct 2003
Posts: 645
Florida
Can we accept a wire that only has the name of the sender and not the address or has the name and the P.O. Box.

We send all the information with our outgoing wires.

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BSA/AML/CIP/OFAC Forum
#343931 - 04/07/05 03:09 PM Re: Travel Rule
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
you can accept it as long as there are no OFAC violations. My understanding of the travel rule is that it is the responsibility of the originating bank to maintain that information. A PO box is an acceptable form of address.
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#343932 - 04/07/05 03:48 PM Re: Travel Rule
Rosebud123 Offline
Platinum Poster
Joined: Oct 2003
Posts: 645
Florida
Thank you so much.

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#343933 - 04/08/05 01:49 PM Re: Travel Rule
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Unless the recipient is not an established customer, the receiving bank's responsibilities for record retention are limited:

(iii) for each transmittal order that it accepts as a recipient's financial institution, a financial institution shall retain either the original or a microfilm, other copy, or electronic record of the transmittal order.

In essence, you keep what you received. There is no implication that you should reject the transaction or are responsible for extracting additional information from the sending institution.

Changing the subject somewhat, it has to be acknowledged that the record retention requirements for funds transfers do not stipulate that an "address" be a physical address. However, I suggest that originating banks require a physical address from the sender and send it along with the wire regardless of what the regulation says.
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