I am trying to find out if a proposed procedure is in violation of any requirement. We are trying to easily identify foreign wire transfers through our wire system so we can generate reports. We want to identify all wires that include a foreign originator, beneficiary or bank. In order to do so it was proposed that if any of the above are foreign we change the country information in the wire to reflect the foreign country. For example, Originator (my customer) with address in the US is sending a wire to beneficiary with US address. Beneficiary's account, however, is in Brazil. Originator and Benficiary addresses are US, but I want to know that the transfer is going to Brazil. Due to systems limitations (I know no one else has those) the proposed option is to change the US country info on the beneficiary to show Brazil. Can I do this (and get away with it)? Additional info, this system is the actual transfer system so this information travels with the wire. Thanks!

Just to make sure I understand your example:

Originating Party's country = US
Originating Bank's (your) country = US
Bene Party's country = US
Bene Bank's country = Brazil

You want to change the Bene Party's country to Brazil, even though the rest of the address says US?

What's the real limitation? You aren't storing countries for parties and banks, just banks? And you have no text or notes fields in the payment system that you can use?

Maybe I'm not getting this, but if you change the beneficiary address I believe you would be playing with the BSA travel rule. If the a/c is in Brazil, why wouldn't the receiving bank show a Brazilian address?

Tahdah,

I'm the Anon (#366596) above. I'm not getting this entirely, and hope that mobdiaz comes back with a little more. I've just spent a couple hundred hours mapping 2 of our wire payment systems into AML monitoring database; so I'm holding back from jumping in with both feet and a boatload of questions about payment systems, data fields, and so on.

I agree that the travel rule is an issue, though I'm not letter perfect in it yet.

From an AML investigation standpoint, though, I'm not at all fond of modifying data in the payment system if its the system of record. Also, if the party and their bank are in two different countries, I want to know that for monitoring purposes.(I know there are tons of good reasons for that to be true, but there are an equal number of bad reasons. You'd be amazed at what turns up if you ask a simple question like, "Show me all the wires that traveled through more than 4 countries between Org and Bene...") Overwriting the Bene party's country would mask that.

From an IT standpoint, my gut tells me that mobdiaz's system probably isn't as constrained as mobdiaz is being told.

From the standpoint of mobdiaz's original question, the information (the bene bank address)is already there to identify the wire as 'foreign'. The bene bank is in Brazil, and that meets the stated goal. So, something else is missing.

So, mobdiaz, please come back,.....

Hmmm, interesting theory, but not sure how you could implement. For example, if I banked at HSBC, I was a US resident, and my account was held in the US, what would it matter if HSBC was not a "domestic" bank? They have a charter in this country for the office I deal with, even though the "home" office is foreign. I could access this account from any HSBC in the world, so an arguement could be made that my account is "foreign." I'm not understanding why you would want to put this procedure in place. Think of the headaches you would cause yourself if you missed one. The regulators would crack down big time on you, if you failed to follow your own internal procedures. But maybe there is more to this than you are letting on.

If you do want to proceed, possibly one easy way to track this is to determine if the funds are in US$, or foreign dollars. Items sent in foreign dollars would be easier to track. This is almost semantics, in that the receiver of the wire is a US bank, just with a foreign home office.