We have customers who will pay for their wires in cash. Are we required under BSA to maintain records and to be able to retrieve the records for cash payments? From my reading it appears that for transfers executed or received for established customers from or to an account at the bank, the information must be retreivable by the name and account number. I am taking this to mean either by debiting an account or payment by credit card. Thank you for your help.

You have to be able to retrieve the record by customer name, and, if they have an account normally used for wire transfers, by account number.

The purpose of the funds transfer record rule is to permit law enforcement to "follow the money" when pursuing an inquiry. The fact that an established customer pays for a wire in cash does not change your needs to keep a record. If anything, you might consider such transaction as questionable, since an established customer would be expected to wire from his/her/its account.

Some banks have strict rules about not accepting cash for wire transfers. They require the customer to deposit the cash and wire from the account.

Has anyone found good software for tracking wires? We are currently entering the information on an Excel spreadsheet, but it would be much less work if we could find a software package that would download the information from the FedLine PC into a database of some type.

I'm with John. We have typically set rules that say no outgoing wires for non-customers and all wired funds must come from an established account. It sure cuts down on a lot of the record keeping.

Bridger Systems, Inc. 800-915-8930 or www.ofaccompliance.com

Our AS400/Jack Henry system has an excellent record keeping function for wire transfers.

I would suggest you look to the software provider for your core applications. As mention Jack Henry has an excellent wire transfer piece that they use in either 20/20 or Silverlake. It works with FedLine so you can upload and download information without rekeying it. And it prepares the required account entries.

Contact BankServ for an excellant system to orginate wires, send to Fed and do all of the tracking you could ever use. They provide an outsource solution. they will do the OFAC verification, check the account balance, and post the transaction as your core system allows.

BankServ
222 Kearny St Suite 414
San Francisco, CA 94108
Phone 415-217-4581
ask for Mary Richards

Can you provide some more information about this. We also use Jack Henry, but I am unaware of this piece and would like to see about getting it added. Thank you.

I'm really going back to the basics here. Is there any thing that defines established customer for wire transfer record keeping. Must this be a deposit account customer, or does loan customer apply?

Try 31 CFR 103.11(l) - "L", not "1".

Thanks - l) Established customer. A person with an account with the financial institution, including a loan account or deposit or other asset account, or a person with respect to which the financial institution has obtained and maintains on file the person's name and address, as well as taxpayer identification number (e.g., social security or employer identification number) or, if none, alien identification number or passport number and country of issuance, and to which the financial institution provides financial services relying on that information.