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BSA/AML Obtaining Purpose for Wire/Funds Transfer

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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.

Obtaining a statement of purpose for a wire transfer is not and never has been a requirement of the Bank Secrecy Act. So, if it was mentioned in your written report it was not tied to a citation for a law or regulation.

My experience is that bankers frequently say their regulator made them do something when in reality the regulator just made a somewhat forceful suggestion.

In my opinion a statement of purpose for a wire transfer is simple due diligence designed to make certain the bank understands how these transactions fit into the customer's business operations. At the barest of minimums, banks should require the information on international wire transfers, but my suggestion would be that the requirement be applied to all wires.

First published on 11/26/12

First published on 11/26/2012

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