BSA: Collecting Required Information For Wire Transfers

Question:

Does the BSA require the originating bank of a wire transfer over $3,000.00 dollars to have both the name and address of the beneficiary?

Answer:

The regulation (31 CFR 103.33) requires retention of several specific pieces of information and then at(F)...

As many of the following items as are received with the payment order:

The name and address of the beneficiary;
The account number of the beneficiary; and
Any other specific identifier of the beneficiary.

Please note the "...as are received.." You are not required to get this information. However, if you do get it, it is subject to the record retention requirements.

I have seen institutions criticized for not following their own procedures when their form requested this information, but they failed to obtain it. The criticism reflects a certain overzealousness...

First published on BankersOnline.com 2/4/02