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#1462747 - 11/02/10 07:59 PM Wire log information
TMichelle Offline
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What information is required to be kept on a wire log?

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BSA/AML/CIP/OFAC Forum
#1462828 - 11/02/10 08:58 PM Re: Wire log information TMichelle
Elwood P. Dowd Offline
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You are not required to have a wire log as such, so there are no explicit requirements. Bank record retention requirements for wire transfers begin at 31 CFR 103.33(e).
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#1462864 - 11/02/10 09:25 PM Re: Wire log information Elwood P. Dowd
TMichelle Offline
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ok, let me put it this way ... what information if any are other banks keeping on a wire log? (If you do not have an automated BSA AML system how would you check 314 request without a log?)

When it (31 CFR 103.33) request you keep the identity of the beneficiary's bank, does that just mean the name of the bank or would it include some sort of address or location for the bank also?

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#1462877 - 11/02/10 09:43 PM Re: Wire log information TMichelle
Kathleen O. Blanchard Offline

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Keep everything required from the travel rule (BSA) and whatever else you need for 314a and any other needs that arise.

Think about what you need, then create the log. The banks I see that retain a log keep travel rule info plus anything else that might be useful.
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#1462934 - 11/03/10 10:36 AM Re: Wire log information Kathleen O. Blanchard
Hrothgar Geiger Offline
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Also keep in mind that under the proposed FinCEN Cross Border reporting initiative, you will have to make an annual report detailing all accounts that originate or receive cross-border electronic funds transfers, and the TIN of the account-holder. So, think ahead to what information will make that report easier to compile each year.

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#1462970 - 11/03/10 12:56 PM Re: Wire log information Hrothgar Geiger
NotDoneYet Offline
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We are regulated by the OCC and the log we keep for BSA purposes includes the originator, the beneficiary, the other bank (if international, the originating not intermediary bank), the state or country, amount, purpose if identified (we require it for international outgoing)and columns to check for OFAC screening.
We keep domestic incoming, domestic outgoing, international incoming and international outgoing separately for easier review.
I can always pull the actual wire document if I need any additional information.

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#1462987 - 11/03/10 01:22 PM Re: Wire log information NotDoneYet
MoodyBlue Offline
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We have automated BSA/AML software that is monitored on a monthly basis. However, our auditors/examiners still require us to keep spreadsheets.
The wire department e-mails daily and I copy the info into an excel spreadsheet. I have a separate spreadsheet for incoming and outgoing wires (domestic and international) with the following info-------Wire Date, Originator, Beneficiary, Adjacent Bank, Bank Location, Payment Method, Account Number, Wire Amount, Fee. I also have a "Comments" column.
Last edited by elvisfan; 11/03/10 01:24 PM.
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#1463964 - 11/04/10 06:02 PM Re: Wire log information MoodyBlue
Lilly C Offline
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We keep an excep log on both incoming and outgoing. on the outgoing we have: date, originator, beneficiary, bank, aba, account number, reference line, wire amount, country.

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#1468857 - 11/17/10 03:28 PM Re: Wire log information Lilly C
TMichelle Offline
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Thanks everyone! We currently have a log that list originator, ssn/tin, acct number, amount, beneficary, bene bank, and country if foreign. Some employees want to stop using the log and go to using system generated reports that only show originator name and address, beneficary name and address (which a lot of time list the bank instead of actual beneficary) and amount. We do not do wires for non customers. We keep all the information on the actual wire request (paper) so they want to stop having to key the information into a seperate spreedsheet "log". I'm just thinking the examiners will not be impressed by this. Any thoughts?

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#1468931 - 11/17/10 03:57 PM Re: Wire log information TMichelle
John Burnett Offline
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Any time you abandon digital methods for keeping these records in favor of paper reports or paper wire requests you lose the ability to "slice and dice" the data, sort it and otherwise massage it to help make it more meaningful. Sure, it's a PITA to key those data into the spreadsheet each day, but it's a heck of a lot easier to do it daily than to try to attack it on a quarterly or less frequent basis.

If you use the Fed for wires, check with your Fed contact to see if there is an option available to map all your incoming and outgoing wire data into a spreadsheet automatically.
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#1471135 - 11/22/10 05:26 PM Re: Wire log information John Burnett
TMichelle Offline
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We do not have Fedwire we use a correspondent bank and the log that generates from their system has limited information. It list the orignator and beneficary and both of their addresses and the date and amount. It does not give an account number, ssn/tin or the other bank's info/location etc. With the travel rule aren't we required to keep this information also? And if yes, does it need to be in the log or can we say "we keep it" by tracing it back to the original paper documents? (i want to keep the log, just preparing myself for their arguments)

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#1471160 - 11/22/10 05:55 PM Re: Wire log information TMichelle
John Burnett Offline
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You can maintain the information in any form you wish, as long as it includes what's required. As for retrievability (this is your key), if you are the sending bank you have to be able to retrieve the info by sender's name and, if the sender is a customer, that account number. If you are the beneficiary's bank, you have to be able to retrieve it by the beneficiary's name and, if a customer, by account number. [31 CFR 103.33(e)(4).

If the data are all in electronic form indexed to name and account number, retrievability seems a no-brainer. If detail is found only in the original paper documents, your retrievability is only as good as your paper filing skills and depends on every piece of that record being returned to the proper place if removed.
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