An auditor raised a BSA question and I'm seeking clarification. We include the originators name and address on all domestic wires (Fedwire system), but for wires done via SWIFT, we only include the originators name, not an address. Is it a BSA requirement to do so? SWIFT says no, auditor says yes. I'm having a hard time deciphering an answer.

We send the originator name and address on all wires. We have ever since the travel rule was instituted. Also we send a large amount of foreign wires and prior to making this mandatory we had several foreign Countries return wires that didn't have the originators name and address. also our system automatically generates a fed cover (if necessary) on our SWIFT's so you need full address on the SWIFT to comply with the travel rule.

I agree with Tahdah. The travel rule requires full information on all wires.

The FATF special recommendations on wires also recommends capturing name and address for both originator and beneficiary. Because of that, as tahdah has mentioned, if you're doing a significant number of international wires, you'll be, er, influenced, to start supplying/capturing that data.