Where can I find anything on the bank altering wire transfer instructions received from a customer?
Can a customer use an ACH credit or incoming wire that has been memo posted to his account? By memo post, I mean it shows as a pending transaction.
Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
Does anyone have a form they use when opening a business account stating they are not an MSB?
What is the reasoning behind one person completing the wire request and a different person posting the wire transfer from an account? Is there a rule or Reg that outlines this dual control? Would we be in any violation if the person taking the wire transfer also posts it to the account? We would have another person balancing the wire General Ledger account daily.
Are banks required to search the OFAC lists on domestic banks when wiring funds?
We disclose that we give same-day availability for cash and wire transfers because the funds are available to the customer if they come into the bank, but they are not available through the debit/ATM card network because we only send a positive balance file after we do our nightly update. Are we out of compliance by disclosing same day availability for these deposits?
Have you heard of a financial institution requiring the beneficiary of a PUPID wire transfer (a non-customer) to complete a form W9 (Request for TIN and Certification) or W8-BEN. I understand the necessity of positively identifying the recipient of the funds but the use of this form seems unusual? I’ve done a little research and cannot find any other references or guidance recommending this. Am I missing something?
I have been finding conflicting information regarding whether a domestic wire transfer can be reversed. Can it be reversed by the customer? What Federal Regulation would wire transfers be governed by?
Where can I find a Risk Assessment Survey form that can be completed by the Bank?