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#1738460 - 09/06/12 04:38 PM Domestic or International
LSmith Offline
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LSmith
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Posts: 703
Scenario: If we have a wire to be sent to a Jacques Daveed at the Bank of Singapore, but Bank of Singapore has a US account at the Bank of New York. Our bank wires money to Bank of Singapore to their account there, with instructions to credit Jacques Daveed. Is this considered an international wire or domestic for our bank?

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#1738463 - 09/06/12 04:40 PM Re: Domestic or International LSmith
Sunshine_101 Offline
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Sunshine_101
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Regulators would argue that even though it went to a US Bank initially, it is still an international wire based on where the funds ended up (Singapore).
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#1738592 - 09/06/12 07:04 PM Re: Domestic or International LSmith
John Burnett Offline
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John Burnett
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The key is where Daveed gets the funds and/or where his account is located. If his account is with the Bank of Singapore in New York, and the funds go to that account, it's not covered by the Remittance Transfers rule. But if his account is "domiciled" in Singapore, and your bank is aware of that fact, that's where he gets the funds, and it's a foreign remittance transfer.
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#1738691 - 09/06/12 09:26 PM Re: Domestic or International LSmith
ItNeverEnds CRCM Offline
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Looking for my sanity
I was just going to post something similar on another foreign remittance thread. I had only been concerned with the wires we had sent using our correspondant bank as far as the new remittance transfer rules. And since we've had well under 100, I wasn't getting too concerned. I hadn't even thought about wires we've sent through the Fed because we considered those "domestic" since the foreign bank had a US correspondant. Only when I read a bulletin from the FRB yesterday did the light bulb come on and I realized that there are situations that we've logged these as domestic and now I'm freaking out as I don't know how we'll be able to go through all the wires and check unless we do it manually.
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#1738816 - 09/07/12 01:49 PM Re: Domestic or International LSmith
ahkcompliance Offline
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Joined: Sep 2008
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Midwest
I was just looking into this same situation. How are we suppose to know if the funds are held in the US or in the country. I will need to do some checking but I think we will still fall under the 100. Most of the wires we send this way are business purpose.

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#1739032 - 09/07/12 05:27 PM Re: Domestic or International LSmith
John Burnett Offline
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John Burnett
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Guess it's a really good thing the effective date was a year out from the Bureau's final rule.
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