We have an audit going on and the examiner is questioning our Wire Policy and 2nd verification of wires i.e., callbacks. It was 'recommended' in our State Audit March of 21. I was new at that time and either it got overlooked or the person who was retiring and I decided not to make any changes. The only wires we would have not signed in person would be for those with repetitive agreements.
"expand the Wire Transfer Policy to define security procedures for verification of electronic funds requests such as call backs – expand Agreements to clearly define the liabilities and responsibilities of all parties – utilize dual controls in the verification of requests".
In our policy, it does state "Depending on the procedures we established with our correspondent bank, call backs or generic email may be used to verify a transaction and/or the wire transfer"
We did update our agreements in March of 2021. Our agreement states " Any wire transfer request, regardless of amount, received by US via facsimile device is subject to a call back procedure in order to further authenticate the request. WE reserve the right to telephonically contact any individual who has signed YOUR request form for the purpose of confirming a transfer request, regardless of amount. If WE cannot obtain a confirmation satisfactory to US, then WE reserve the right to refuse to honor any wire transfer request. WE have no responsibility to verify the identity of any party identifying them self as an individual authorized to receive a telephonic confirmation of any wire transfer request, other than to verify that the name given by such party corresponds to a party that has provided his or her signature on this wire Agreement."
What am I missing? Thanks!
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