I am currently conducting a BSA audit. As part of the process, I am reviewing wire transfer procedures as it relates to BSA. It is my understanding that according to the the regulation, records must be retrievable by the name of originator (for originated transfers) and name of beneficiary (for received transfers), and, if they are established customers, by account number. Currently, our files are simply maintained collectively by month and day.

How are your institutions meeting the information retrievability requirement noted above?

We keep a wire log in Excel that allows us to find any wire by each of the required designations. From that data, we are able to access the date, etc. to locate the actual wire documentation.

We use an Access database that someone designed several years ago. The database is used to input the information for outgoing and incoming wires and prints the form to initiate the wire. You can click in any field and perform a search.

Can you point out the reg section that "requires" retrieval by name? I must have missed that one.

Ipso,

Bank Secrecy Regulation. Specifically Section (4) Retrievability.

MarkB

Viable options depend upon the amount of wire activity you have. The reg only requires that you be able to research and retrieve information in a reasonable period of time...not instantly. For a very small shop with limited wire activity, you may easily be able to do a manual search of your records (wire write-up forms). The next level may be a hand written log with the appropriate information on it. Beyond that, consider a log based on Excel, Access, or other software program that will allow searching capabilities.