I'm having a hard time wrapping my brain around this deciding if there is a violation of the Travel Rule or not.

Bank A is a small community bank. All wire requests are received from their customers, documented on a wire form, and then phoned in to Bank B. Bank B then sends the wire onto the beneficiary bank. When Bank A phones the wires in to Bank B, they are not providing customer address and account number to Bank B.

I don't believe Bank A is complying with Travel Rule requirements, but they are telling me that Bank B is considering themselves the transmitting FI with Bank A being the transmittor. However, on the confirmations received from Bank B, Bank A's customer is listed as the Originator and Bank A is the Originator FI.

I guess my question is when a bank is not processing their own wires, but sending information to another bank, does all of the required Travel Rule information need to be sent? Who is in violation of the Travel Rule here? Bank A, Bank B, or both?

Thanks in advance.

Anyone? If I need to clarify anything, please let me know.

see if this helps... https://www.sec.gov/about/offices/ocie/aml2007/fincen-advissu7.pdf

and i've selected snipped a bit:

Only transmittals of funds equal to or greater than $3,000 (or its foreign equivalent) are subject to
this rule, regardless of whether or not currency is involved. In addition, transmittals of funds governed
by the Electronic Funds Transfer Act (Reg E) or made through ATM, or point of sale systems are not
subject to this rule.

An intermediary financial institution must pass on all of the information it receives from a transmittor’s
financial institution or the preceding intermediary financial institution, but has no general duty to retrieve
information not provided by the transmittor’s financial institution or the preceding intermediary financial
institution. Exceptions are noted below.

However, if the system used to effect the transmittal of funds is not currently designed to enable these
requirements to be met, the name, address, account of the transmittor and the identity of the transmittor’s
financial institution need not be passed on until such time as the bank that sends the order (to the Federal
Reserve Bank or otherwise) completes its conversion to the expanded Fedwire message format

Thanks Happy. I'll check it out.