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#1509689 - 02/14/11 03:40 PM Keeping records of refused wire transfer requests
Irishguy Offline
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Irishguy
Joined: Aug 2008
Posts: 613
Kentucky
I'm working on a wire transfer audit and one of the questions in my work program wants to know if the bank keeps sequential records of refused wire transfer requests.

Is this a requirement? If so, can someone provide a site for me.

If this is not a requirement, can anyone help shed some light on why the audit work program would want to know if we keep these requests? I'm guessing it may be a BSA/AML issue, but that is all I'm coming up with this morning.

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#1509839 - 02/14/11 06:26 PM Re: Keeping records of refused wire transfer requests Irishguy
Hobbes Offline
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Refused by who? Did your bank refuse to process the request? or did the receiving party refuse to accept? I don't think I've seen that question before in a wire transfer audit program, that's why I'm asking who refused.
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#1509852 - 02/14/11 06:43 PM Re: Keeping records of refused wire transfer requests Hobbes
Irishguy Offline
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Irishguy
Joined: Aug 2008
Posts: 613
Kentucky
I'm guessing it would be the originating bank refusing to process.

This may be a BSA issue. For example, let's say we get a hit on the OFAC list for the beneficiary. We would not process this transaction.

I believe my audit workpapers are stating that we should keep a record of this, but I can't find anything that states this is a requirement.

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#1509907 - 02/14/11 07:51 PM Re: Keeping records of refused wire transfer requests Irishguy
Hobbes Offline
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Hobbes
Joined: Sep 2007
Posts: 126
On a sled
I agree that it may be BSA/OFAC related, but I don't know of any requirement for this. I haven't seen anything in the FFIEC's BSA manual on this. It sounds like a good business practice, but I don't understand the "sequential" bit.

Sorry, but I wasn't any help on this. Good Luck.
Last edited by SC Buckeye; 02/14/11 07:51 PM.
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