Question: Regarding "Travel Rule" compliance, does anyone have an example of (f)(1)(vi)(C)"Any other specific identifier of the recipient"? For instance, could special instructions be considered a "specific identifier of the recipient"?

Your citation is off, but the travel rule does require the transmission of "any other specific identifier of the recipient" (in addition to name and address) if it is received. To my knowledge there is no official interpretation or example.

From my perspective, it focuses only on information that would help in identifying the individual or the entity that is to receive the proceeds of the wire. Examples are difficult to come by, but a phone number might qualify. In simpler times (when this regulation was written), if the bank was sending a PUPID wire, it might have included the beneficiary's SSN, DL number or a portion of either. That's hard to imagine now.

A failure to include instructions requested by the originator; e.g. a reference to an invoice number, would be a customer service error, but would not be a violation of the travel rule.

If you want a more authoritative opinion, try the Helpline.

Thanks for your input Ken. We've had a disagreement over the definition of identifier vs. instructions. Audit says specific identifier of recipient includes instructions.

Honestly, I always wondered about the value of this "travel" requirement, but never had a question about it before so I spent more time on this than I would care to admit. I concluded that it makes little sense.

Today, due diligence (not in vogue when this regulation was spawned) would prompt the originating bank to obtain identifying information for the beneficiary even though it is not required by the regulation. However, if the beneficiary bank is dealing directly with the recipient, it has the ability to require whatever information it might need.

So: What's the point in requiring the originating bank to provide the beneficiary bank with information on its own customer?

Audit says specific identifier of recipient includes instructions.

OK - so let's for a minute say Audit is correct. When was the last time the customer provided you specific instructions to send to the receiving bank or beneficiary with the wire and you didn't send them???

I don't understand what the issue is either way????? You send what you receive in the wire instructions from the customer and you retain all information on incoming wires. What is the point of this disagreement??

We are trying to determine if there was a violation of travel rule if, for example, the "invoice number" did not travel with the wire. The auditor says the invoice number is a specific identifier of the recipient.

OK - The auditor is certified nuts.

The question becomes though, why would the instructions from the customer not travel with the wire and if it was not meant to travel with the wire, what it is doing in your files.

are they under the assumption that if you alter the wire instructions for minor items what else is the bank altering?

http://graphics8.nytimes.com/images/2009/01/10/business/lloyds_final_press_release.pdf

Duh, the recipient's DOB would also be an identifier for an individual. Again, I don't see it's use being likely today.