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#1073622 - 10/30/08 04:43 PM Wire Transfer with PO Box
Texas53 Offline
Junior Member
Texas53
Joined: Jun 2008
Posts: 41
TEXAS
Just checking to see if a Phyical address is required for Wire Transfer or can a PO Box be used? This is for outgoing and incoming.

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#1073805 - 10/30/08 06:15 PM Re: Wire Transfer with PO Box Texas53
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I believe it's OK. From the FFIEC Exam Manuel...

Customer Address

The term “address,” as used in 31 CFR 103.33(g), is not defined. Previously issued guidance from FinCEN had been interpreted as not allowing the use of mailing addresses in a transmittal order when a street address is known to the transmittor’s financial institution. However, in the November 28, 2003, Federal Register notice,96 FinCEN issued a regulatory interpretation that states the Travel Rule should allow the use of mailing addresses, including post office boxes, in the transmittor address field of transmittal orders in certain circumstances.

The regulatory interpretation states that, for purposes of 31 CFR 103.33(g), the term “address” means either the transmittor’s street address or the transmittor’s address maintained in the financial institution’s automated CIF (such as a mailing address including a post office box) as long as the institution maintains the transmittor’s address97 on file and the address information is retrievable upon request by law enforcement.

96 68 Federal Register 66708.

97 Consistent with 31 CFR 103.121, an “address” for purposes of the Travel Rule is as follows: for an individual, “address” is a residential or business street address, an Army Post Office Box or a Fleet Post Office Box, or the residential or business street address of next of kin or another contact person for persons who do not have a residential or business address. For a person other than an individual (such as a corporation, partnership, or trust), “address” is a principal place of business, local office, or other physical location. However, while 31 CFR 103.121 applies only to new customers opening accounts on or after October 1, 2003, and while the rule exempt funds transfers from the definition of “account,” for banks, the Travel Rule applies to all transmittals of funds of $3,000 or more, whether or not the transmittor is a customer for purposes of 31 CFR 103.121.
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