Has anyone ever heard of keeping additional records, like for wire transfers of $3,000 or more, for internal transfers between non-related accounts for the same dollar amount? This is discussed in a paragraph of our existing Wire Transfer Policy that our BSA Officer and I have recenty inherited from someone who has retired. Thanks.

Actually, the very rule under which you are keeping records of $3,000 and up wire transfers ( Section 103.33(e) of 31 CFR Part 103) does not limit its scope to wire transfers. It covers funds transfers of all types, except those covered by Regulation E and ACH items. So if the accounts involved are not consumer accounts or if the transfers aren't covered by Reg. E or effected via the ACH, they are subject to the rule.

Records, schmecords. Everybody has records.

The problem is retrievability. Since you are both the Originating Bank and the Receiving Bank, you have to be able to retrieve information under either name and either TIN.

Al

I guess I'm still confused. Other than a wire transfer, could you give me an example of a transaction where this applied?

You might be having trouble thinking of an example because your bank doesn't permit such things, but consider the situation in which a single individual owns several small LLCs or corporations, the sorts of things that would have been sole props before LLCs became so popular. Somehow the individual convinces the bank to permit him to make inter-company transfers using online banking.

That sort of transfer would require the appropriate record keeping and retrieval capabilities under 31 CFR 103.