Our BSA Department uses a wire report to review international wires based on countries. We came across a wire where the originator has an address in Saudi Arabia but he used a bank in Hong Kong according to the swift code. The wire department is telling us that the wire should be coded as coming from Hong Kong. We say that it should be coded as coming from Saudi Arabia. What do you all think? Should we base it on the originator's address or the originator's financial institution address? Thank you.

The wire originated from where the wire originated. The address given by the originator is a totally separate issue.

This is a little far fetched, but do you want to code a wire as domestic if I am in Syria and initiate a wire - I don't think so.

Having worked both departments, I have always stood a firm ground on using the Originating FI location. This conclusion stemmed from the domestic vs international point. We have several customers (consumer and business) with foreign addresses and domestic accounts, where funds are maintained for domestic use only, despite a foreign location. We utilized this thought process across the board for scenarios similar to the one you've listed. Personally, I would code as Hong Kong, but that is solely my opinion.

I recently went through our foreign wires for a report and I agree with both Infernalflora and rlcarey. Many times a customer will wire funds to himself internationally but use his domestic address for beneficiary's address. It looks by address as domestic to himself but it is foreign. The address is information that is relayed by customer, I would follow what your wire department states.

Your customer may be from Saudi Arabia, but as expat in Hong Kong and has established bank account in that country. The funds could originate in Hong Kong and have no tie to Saudi.

IMHO, you can show the wire came from Hong Kong, but you cant show that it came from Saudi, just the address of the customer is in Saudi.

I think there may be some confusion about the type of "coding" going on here. For SWIFT processing, it should be based upon the FI location. For OFAC and AML purposes, all geographic factors should be considered; however, my opinion is that it is preferable to use the originators location when monitoring suspicious activity.