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#1236034 - 08/20/09 03:06 PM PUPID Wire Transfer -CTR
BSA Auditor Offline
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Joined: Aug 2009
Posts: 9
We disburse PUPID wire transfers with a Cashier's Check. In cases where the payee asks to cash the check, does the CTR box 30 need to be checked to show incoming wire transfer in addition to checking box 32 for negotiable instrument cashed?

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#1236042 - 08/20/09 03:09 PM Re: PUPID Wire Transfer -CTR BSA Auditor
John Burnett Offline
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John Burnett
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Posts: 39,785
Cape Cod
No. The transaction being reported is the cashing of the check. The bank records will tie that check back to the incoming wire, if necessary.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1236242 - 08/20/09 05:00 PM Re: PUPID Wire Transfer -CTR John Burnett
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Posts: 9
Thank you.

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#1236335 - 08/20/09 06:33 PM Re: PUPID Wire Transfer -CTR BSA Auditor
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
As a side question, I don't know of many banks who continue to accept PUPID wires; how do your regulators view this activity?

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#1236664 - 08/21/09 11:50 AM Re: PUPID Wire Transfer -CTR devsfan
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
Next to Harvey
From Appendix H (Request Letter) to the BSA/AML Examination Handbook:

Funds Transfers

_ Funds transfer activity logs, including transfers into and out of the bank. Include the number and dollar volume of funds transfer activity for the month.
_ List of funds transfers purchased with currency over a specified time period.
_ List of noncustomer transactions over a specified time period.
_ If not already included in the BSA/AML policies, make available copies of any policies, procedures, and processes related to funds transfers or payable upon proper identification (PUPID).
_ List of suspense accounts used for PUPID proceeds.
_ List of PUPID transactions completed by the bank, either as the beneficiary bank or as the originating bank

To illustrate the likely regulatory attitude, emphasis has been added to the number of pre-exam questions focused on dealing with non customers and wires. I would have thought that a non customer wire that could either begin or end with a reportable amount of currency would be outside anyone's boundaries.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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