An internal audit found the beneficiary of an incoming wire transfer deposit was an authorized signer, not the owner of the account.

We do not conduct CIP on authorized signers, only owners of the account.

Would this violate any BSA regulations?

It would violate your own policy, - since you must have stated in your policy that authorized signers are not customers, - therefore you do not CIP them.

You are therefore accepting a wire for a non customer.

If your policy states that you do not do business with non customers you have just violated your own polciy.

Thanks, I agree. Just wanted to be sure before I take on the operations department.

We have this same issue, and it was something the OCC caught when they were in last time. We are implementing a software enhancement with our wire automation vendor to catch those and kick them out for review prior to posting to a customer's account. We do pretty significant wire volumes (30-40K p/month) so it wasn't something we could control without a technology solution.

Also, if you deposited it into the business account, the signer could have a claim against you.