My wire department is telling me that the Travel Rule only applies to foreign wires. I'm not reading it that way. Can anyone confirm this for me?

As far as I'm aware the Travel Rule applies to ALL wires for $3,000 and more.

Doug is correct.

Yep, I agree. It applies to all wires.

If such words of limitation exist it should be easy for your wire department to point them out to you. They don't.

The notice of proposed rulemaking on the reporting of cross border electronic transfers would create a structure that will make your compliance with the travel rule on these wires even more critical.

I am actually in the middle of a wire audit myself. Should I be looking for all of the items included in the travel rule for incoming wire transfers. In a few cases, the beneficiary address is not on our incoming wires. Your thoughts?

The originating bank is only required to send the beneficiary address if they receive it.

You are the receiving institution; you are in no position to compel the originating bank's compliance with the travel rule.

I was under the impression that the travel rule applies to (I)ACH as well.

Was there something in the rule itself or the subsequent guidance that led to that impression?

I thought I saw something in that regards in the NACHA website.

12. Does NACHA require Travel Rule information for all IAT transactions or only for those that exceed $3,000? While BSA only requires Travel Rule information when a funds transfer exceeds $3,000, the ACH Rules require this information for all
IAT entries.



http://admin.nacha.org/userfiles/File/IAT_Industry_Information/docs/IAT_FAQs_2_4_09.pdf

I see. You confused a NACHA rule with a BSA regulation.

I would not be to sure about that one, as ACH transactions are funds transfers as per FRB.

Effective September 18, 2009, all international transactions made via the ACH Network will be required to use the IAT SEC code. This new rule applies to all ACH participants and will simplify the process of identifying international transactions by requiring that IAT entries include specific data elements defined by the Bank Secrecy Act’s (BSA) “Travel Rule.” This will make it easier for depository financial institutions to comply with U.S. laws, such as requirements by the Office of Foreign Assets Control (OFAC). The new rule will also define new parties to the IAT entry and re-define gateway operator obligations. Ultimately, IAT will complement other network formats and enhance processing efficiencies for all ACH participants.

http://www.frbservices.org/eventseducation/education/iat_overview.html

There seems to have been a change

1996
http://www.fincen.gov/news_room/rp/advisory/html/advissu3.html

§ 103.33(e)(6) Exceptions.


Q29: What types of transfers are excepted from the rule?

A29: The following transfers are excepted from the rule:

i) transfers of less than $3,000;

ii) debit transfers;

iii) transfers governed by the Electronic Fund Transfer Act, as well as any other funds transfers made through ATM, ACH, and POS systems;

http://www.gpo.gov/fdsys/pkg/CFR-2010-title31-vol1/xml/CFR-2010-title31-vol1-sec103-33.xml

F) As many of the following items as are received with the payment order: 1

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Footnote(s):1 For funds transfers effected through the Federal Reserve's Fedwire funds transfer system, only one of the items is required to be retained, if received with the payment order, until such time as the bank that sends the order to the Federal Reserve Bank completes its conversion to the expanded Fedwire message format.
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(1) The name and address of the beneficiary;
(2) The account number of the beneficiary; and
(3) Any other specific identifier of the beneficiary





6) Exceptions. The following funds transfers are not subject to the requirements of this section:
(i) Funds transfers where the originator and beneficiary are any of the following:
(A) A bank;
(B) A wholly-owned domestic subsidiary of a bank chartered in the United States;
(C) A broker or dealer in securities;
(D) A wholly-owned domestic subsidiary of a broker or dealer in securities;
(E) A futures commission merchant or an introducing broker in commodities;
(F) A wholly-owned domestic subsidiary of a futures commission merchant or an introducing broker in commodities;
(G) The United States;
(H) A state or local government; or
(I) A Federal, State or local government agency or instrumentality; or
(J) A mutual fund; and
(ii) Funds transfers where both the originator and the beneficiary are the same person and the originator's bank and the beneficiary's bank are the same bank.
(f) Nonbank financial institutions. Each agent, agency, branch, or office located within the United States of a financial institution other than a bank is subject to the requirements of this paragraph (f) with respect to a transmittal of funds in the amount of $3,000 or more: