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#2138051 - 07/13/17 09:50 PM Wires (Cash deposited to an account)
Tabbetha, CRCM Offline
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Joined: Feb 2009
Posts: 44
Mississippi
We debit an account to send wires. If a wire is sent from a GL account it is for loan proceeds. If a customer has cash it must be deposited to their account. Would this still be considered a wire funded with cash since it was deposited to an account first?

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#2138053 - 07/13/17 10:08 PM Re: Wires (Cash deposited to an account) Tabbetha, CRCM
Daisy Doodle Offline
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Southern U.S.
Yep.

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#2138058 - 07/13/17 10:43 PM Re: Wires (Cash deposited to an account) Tabbetha, CRCM
TryingtoComply Offline
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The West
Does your AML monitoring software allow you to establish a rule to identify these types of situations? If it doesn't, be sure to train your employees to report these types of transactions to your BSA Department.
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#2138138 - 07/14/17 03:40 PM Re: Wires (Cash deposited to an account) Tabbetha, CRCM
edAudit Offline
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edAudit
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yes, also make sure that the bank can:

Retrievability

Information retained must be retrievable by reference to the name of the originator. When the originator is an established customer of the bank and has an account used for funds transfers, information retained must also be retrievable by account number (31 CFR 1010.410(a)(4)). Records must be maintained for five years.

https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_025.htm
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#2138148 - 07/14/17 03:53 PM Re: Wires (Cash deposited to an account) Tabbetha, CRCM
Elwood P. Dowd Offline
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Following FinCEN's guidance on this specific point may be a bit treacherous.

There is guidance that says cash deposited to an account and later debited to purchase an official check should be shown on a CTR as the purchase of an official check with cash. (Dumb, but true nevertheless.) It would be easy to follow the same logic here.

However, when you send the wire, the travel rule requires you to include the customer's account number if the account was the source of the funds. There, I would not treat the wire as if it was purchased with cash and would include the customer's deposit and loan account numbers. The GL account number doesn't tell anyone anything.
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#2138158 - 07/14/17 04:18 PM Re: Wires (Cash deposited to an account) Tabbetha, CRCM
Tabbetha, CRCM Offline
Junior Member
Joined: Feb 2009
Posts: 44
Mississippi
Thank you all. This is very informative.

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