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#2255762 - 06/22/21 08:35 PM Incoming Wire question
Megaman Offline
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Joined: Jul 2017
Posts: 116
I have auditors trying to write me up for two incoming wires where the name and address of the Beneficiary and originator were not included in the wire. Is it a requirement that this information be included and that the receiving Bank have this information? There thoughts are that we are not running an OFAC check on the beneficiary and originator. Our parameters are set up so that if the information is there OFAC is being checked on these areas. Is this a violation of BSA rules and regulations? Any thoughts? This just does not seem right to me. If I am suppose to have this information and it does not come with the wire transfer are we suppose to reject the wire? The routing number and account number are correct. I am not sure what I am to do in this situation. Any guidance would be greatly appreciated.

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#2255764 - 06/22/21 08:47 PM Re: Incoming Wire question Megaman
ACBbank Offline
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Joined: Jul 2006
Posts: 4,138
New York City
I'm not sure why you would accept a wire without the name of the beneficiary? I guess that's a different thread though. You can check the Travel Rule on what is required for funds transfers.

Regarding OFAC - if ABC is your customer and ABC is the beneficiary of the wire and you're screening your customer base against the SDN List on a weekly basis I think the odds that the beneficiary of the wire being a sanctioned party is slim. The risk is there, but it's minimal.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2255773 - 06/23/21 12:30 PM Re: Incoming Wire question Megaman
edAudit Offline
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Joined: Jul 2008
Posts: 4,761
You are here
My question would be is there no beneficiary on the wire or is the beneficiary in the incorrect field?

As for OFAC the customer should be the beneficiary as such you should be conducting OFAC during normal banking processes.

I would want to know why they wires were sent with no beneficiary as it could be a fraud situation.

It has been a long time since I have seen a missing beneficiary yet alone 2 in the same audit cycle.
Opinions can be considered as coming from anywhere but my employer.


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#2255823 - 06/23/21 06:34 PM Re: Incoming Wire question Megaman
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,417
Pulling people out of the ditc...
simply ask your auditors to provide the regulatory citation that states you may not accept wires as you describe. then smile and go on your way.
Providing alternative truths since the invention of time

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