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BSA Travel Rule-Complete Wire Originator's Address

For the BSA Travel Rule, we need regulatory guidance on what is considered a complete Wire Originator's address. Is it the street address, city and state, or does the address need to include a ZIP code? I can't find any definition of what a complete address is in the regulation.

by Ken Golliher:

I typed "500 Baxter Street New York" into MapQuest. It gave me multiple options. You need a city and a zip code.

The record retention requirements for wire transfers (which drive the travel rule) predate the CIP regulation. It says you must have the originator's address, but does not stipulate that it must be a physical address. As most banks only send wires for their own customers obtaining a physical address is not a problem, but that does not mean you must send the physical address with the wire.

As a matter of routine practice, I suggest you send the physical address with the wire. If the customer has a reason why they do not want the physical address sent I would certainly listen. However, if your forms and procedures require a physical address you're stuck.


Answer by John Burnett:

If you are the beneficiary's bank, the travel rule requires that you retain either the original or a copy, or an electronic record of the payment order. It does not say that you must obtain the originator's address if it's not included in the wire record. But if you are the originator's bank, you have to obtain the address and include it in your record of the order.

First published on 03/18/2018

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