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BSA Hold On Incoming Wire for More Information

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Question: 
When BSA holds an incoming wire because they need more information such as invoices, It is our procedure to send a service message to the originating bank and ask for that required info. Sometimes, we are asked to contact the customer and ask for that information from the customer. Is that against any violations or do you think that could offend the customer in any way? Should a specific dept like BSA, contact the customer for that information to avoid having a dept like customer service, that doesn't have any knowledge on that, say something incorrect?
Answer: 

Start with the idea that there is no such thing as a "BSA Hold."

Someone in your bank is a bearcat for nerve if they believe they have any right to hold the proceeds of an incoming wire without significant evidence of wrongdoing.

Regardless of who reaches out for additional information, it makes very little sense to contact the originating bank. Cautious originating banks sometimes require copies of invoices, but I've never heard of a beneficiary bank making such a request. The originating bank probably will not have the information and might reasonably choose not to make it available to you if they did.

It's your customer whom you should be talking to.

I can make an argument that the people who are going to be evaluating the answers should be the ones asking the questions so we don't have a lot of "Well, go back now and ask them this." However, that's a common problem and I cannot resolve it.

First published on 10/29/2017

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