Our BSA auditors (not examiners) provided the Fincen advisory FIN-2014-A006, jurisdictions with AML/CFT deficiencies and made the following recommendation "Management develop and implement procedures, etc, to identify funds transfers from those countries (which we would see during our wire log review anyway) and due diligence should include, at a minimum, identification of the source of the funds (impossible on an incoming wire and the customer must have available funds in an account for an outgoing wire), documentation to support the purpose of the transfer (so on an incoming wire, call our customer prior to posting to ask why they received the wire from Turkey?????) and whether any significant cash activity is involved for a period of time before and after the transfer. An explanation between the beneficiary and originator should be documented as well. I agree overkill on all counts but was curious how others handled this.