A customer of ours wishes to have its physical address remain anonymous when conducting a wire and only provide their PO Box.

We would maintain the customers physical address on file and it would be available for law enforcement.

Are we able to comply with our customer's request and still be in compliance with Funds Transfer Recordkeeping and the Travel Rule?

BSA's record retention requirements for wire transfers do not require that the address you keep for a customer be a physical address. The travel rule does not require that it be a physical address that travels with the wire. The relevant warning from the November 2010 FinCEN Guidance on the travel rule is:

For purposes of compliance with the Travel rule, the use of a code name or pseudonym is prohibited. In all such cases, the financial institution must use the customer's true name, and the customer's address.

At a minimum, I would say the address you use must be one that your bank knows to be valid based on your business dealings.

I would supplement that warning with another, please review your related forms and procedures to make certain you do not have an internal requirement to retain (and thus send) a physical address with your wire transfers. As long as you only send or receive wires for your own customers you should have a physical address available, but any third party reviewer might think it odd that you are not requiring a physical address and ask you to prove your point. If you think this one customer is worth the precedent, be prepared for its expansion with others.

As a personal observation only: If you give me your customer's name and city, it's pretty likely that I can come up with his address. Giving it to another bank and, perhaps, the person he sent a wire to, is not exactly a significant disclosure unless the customer has made a claim for grace in connection with CIP under the FinCEN guidance regarding individuals who have been abused.