Posted By: #12
Travel Rule help - 05/10/19 05:57 PM
I'm having a hard time wrapping my brain around this deciding if there is a violation of the Travel Rule or not.
Bank A is a small community bank. All wire requests are received from their customers, documented on a wire form, and then phoned in to Bank B. Bank B then sends the wire onto the beneficiary bank. When Bank A phones the wires in to Bank B, they are not providing customer address and account number to Bank B.
I don't believe Bank A is complying with Travel Rule requirements, but they are telling me that Bank B is considering themselves the transmitting FI with Bank A being the transmittor. However, on the confirmations received from Bank B, Bank A's customer is listed as the Originator and Bank A is the Originator FI.
I guess my question is when a bank is not processing their own wires, but sending information to another bank, does all of the required Travel Rule information need to be sent? Who is in violation of the Travel Rule here? Bank A, Bank B, or both?
Thanks in advance.
Bank A is a small community bank. All wire requests are received from their customers, documented on a wire form, and then phoned in to Bank B. Bank B then sends the wire onto the beneficiary bank. When Bank A phones the wires in to Bank B, they are not providing customer address and account number to Bank B.
I don't believe Bank A is complying with Travel Rule requirements, but they are telling me that Bank B is considering themselves the transmitting FI with Bank A being the transmittor. However, on the confirmations received from Bank B, Bank A's customer is listed as the Originator and Bank A is the Originator FI.
I guess my question is when a bank is not processing their own wires, but sending information to another bank, does all of the required Travel Rule information need to be sent? Who is in violation of the Travel Rule here? Bank A, Bank B, or both?
Thanks in advance.