How do banks that scan their wire transfers handle the retrievability requirement of keeping the records alphabetically and in account number order? Or would this requirement apply since you would be able to search either way for these records?
The BSA Exam Manual discusses keeping records alphbetically and in account number order:
Retrievability Information retained must be retrievable by reference to the name of the originator. When the originator is an established customer of the bank and has an account used for funds transfers, information retained must also be retrievable by account number (31 CFR 103.33(e)(4)). Records must be maintained for five years.
Would you have to keep them both ways or as are you in compliance as long as you can retrieve them either way?