We had a non-customer bring in over $10,000 in cash for a wire transfer. This individual has a post office box, but lives "off the grid" with no physical address. He did present a valid drivers license from another state with a physical address. We know this person has lived at the current location for several years now.

My question is this: Does the PO Box trump the "no longer living there" physical address? I'm leaning toward the PO Box as it is more relevant than an old physical address, but we all know common sense doesn't always come into play

common sense?

Common Sense suggests that a bank would not conduct a wire transfer for a non-customer. And that would be doubled if it involved cash over $10,000.

A PO Box is not an address.

Sec. 1010.312 Identification required.


Before concluding any transaction with respect to which a report is required under §1010.311, §1010.313, §1020.315, §1021.311 or §1021.313 of this chapter, a financial institution shall verify and record the name and address of the individual presenting a transaction, as well as record the identity, account number, and the social security or taxpayer identification number, if any, of any person or entity on whose behalf such transaction is to be effected.

As I'm sure you know, the BSA Officer is left to file the reports (emphasis on the "s") because they were not consulted prior to the transaction.

Staff was questioned and there is no known physical address for this person living miles from town with trails being the only access to their "homestead". So it wasn't that we didn't ask, a physical address just doesn't exist.

I've heard that a physical address in a case like this could be something like "1.2 miles down dirt road going north from Highway XXX at milepost 123.4". I've never had to use an address like this, so I'm not completely sure, but as long as the description is specific enough....

I am well aware of the challenges, but what I was suggesting is that you have a serious deficiency in your bank policy if you are allowing non-customers to perform wire transfers. Not only are you faced with this issue when you have to file a CTR, but also for the $3,000-$10,000 wire transfer recordkeeping requirements. Since this guy lives up a path somewhere, how did he amass that amount of cash? You now have the same issue when you begin your SAR investigation in determining the legitimacy of the funds for this transaction - you have no where to start.

Thanks for the insite Mike.

I couldn't agree with you more rlcarey! I'm just trying my best to report the information I do have

I'm sure when the regulators come calling, you will be comfortable answering with "but we've always done it like this."

in this case, the horse has already left the barn so closing the door is not an option. I'd suggest including the deficiencies on the address in the narrative.

you have several issues that I think you know need addressing moving forward:
-changing policy so wires are not performed for non-customers
-all wires are done via a DDA or SAV account, where funds are deposited to said account and account debited. no accepting cash for wires
-verifiable street address required, not drive down hwy 26 to 3rd oak tree and turn left
-training for branch/retail staff so they understand why
-we've always done it like this is not a sufficient training plan

The address should be sufficiently specific that a law enforcement officer could drive/walk to the location and expect to find the person of interest.