Where is that "Wire Transfer" Rule?
Confusion abounds in the wire transfer compliance department. Wire transfer rule changes have been talked about for so long that everyone thinks they missed the final. There is no final revised rule yet. The unofficial word from the officials is "don't plan a vacation around Memorial Day!" We can expect a final rule in the next month or so to take effect in late May.
In the meantime, you should be maintaining information on any electronic or wire transfers in excess of $3,000 and be able to retrieve information about the transfer.
It is also important to remember that the purpose of this rule is to provide a trail for transactions that are not paper based. It will therefore apply to any electronic transfer meeting the minimum amount, not merely those carried out by wire.
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 6, 4/96