We are the beneficiary bank and there is an intermediary bank. Sometimes we do not recieved the address of the client, but we want it for BSA purposes. Can we require this? If the originating bank is required to provide it, why aren't we getting it?

Under the Travel Rule, the intermediary bank is required to pass along what they received. So, if they received the bene's address, they should pass it along.

But as the beneficiary, if we do not receive this aren't we required to obtain it.

not unless you are a bank in either Canada or China. As the beneficiary bank, though, wouldn't you receive a beneficiary name and account number? How else do you effect payment?

We get a name and account number, but sometimes not an address. I recently had an examiner ask me about the addresses, so it made me wonder if I was going to be held responsible if I didn't have them?

I'm sorry, I must be missing something. You are the beneficiary's bank, you receive the beneficiary's name and account number on the wire transfer message, correct. You already know the beneficiary's address, because they are your customer, with an account on your books.

Sorry I meant the originator. We get a name but no address.

My mistake then. It's certainly your prerogative to hold the payment until you receive full originator details.

Are you sayiing that if the originator's address is not shown on an incoming wire you would hold it? It sounds like you are creating an awful lot of work for little benefit.

No, that's not what I said at all.