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#1283024 - 11/06/09 09:53 PM Regulation GG and FedWire
YosemiteSamIAm Offline
Power Poster
Joined: Jan 2004
Posts: 2,795
Has anyone received assurances from FedWire that they are blocking wires related to illegal Internet gambling? If so, when/how was the communique transmitted? Thanks!
Sorry, did I just use my outside voice?

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Operations Compliance
#1283174 - 11/07/09 09:00 PM Re: Regulation GG and FedWire YosemiteSamIAm
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
It's literally an impossibility that any wire system could identify and block wires in process that are derived from gambling, legal or otherwise. Only the card system has that capability and it is dependent on the proper use of codes.

Regulation GG only contemplates the possibility that the card system will offer assurances.
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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#1283635 - 11/09/09 08:00 PM Re: Regulation GG and FedWire Elwood P. Dowd
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,794
Pulling people out of the ditc...
FRB will not be doing this, any more than they scan wires for OFAC compliance...
Providing alternative truths since the invention of time

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#1283711 - 11/09/09 08:44 PM Re: Regulation GG and FedWire HappyGilmore
beth@pcb Offline
New Poster
Joined: Aug 2006
Posts: 8
The sample policy I looked at on BOL says "the bank is not required to block ACH, wire, or check payments..."
Is this true? Are we only supposed to be concerned with debit/credit card transactions? What about the "designated payment systems" mentioned in the reg?

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#1284148 - 11/10/09 03:02 PM Re: Regulation GG and FedWire beth@pcb
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
As a beneficiary's bank under a wire system such as FedWire or SWIFT you are expected to have a program in place that is reasonably designed to block or otherwise prevent your customer from receiving a wire transfer that is a restricted transaction.

There is no way for you, as the beneficiary's bank, to know the purpose of an incoming wire. Therefore your reasonably designed program has to focus on preventing a commercial customer from accessing incoming wire transfers. The procedures for such a program would ordinarily consist of a series of customer due diligence vetting questions used to determine whether a prospective commercial customer will be engaged in the business of Internet gambling, and, if yes (and if the bank wants to pursue the account relationship further), whether that Internet gambling business is legal (licensed). Put more simply, your procedure would be designed to prevent the bank from accepting as a customer a commercial enterprise that might operate an illegal Internet gambling business.

I'll be re-presenting my "Blocking Internet Gambling -- Are You Ready?" webinar on November 19. You should see a link to the program information to the left of these Threads.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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