International Wires - Checking 311 Entities

Answered by:

Question:

Are banks required to check the entities listed in section 311 of the USA Patriot Act every time an international wire is sent or received, and is this part of the FFIEC Examination Manual?

Answer:

Best practice is to add the special measures entities and countries to the list against which wires are scanned. It is the only reliable way of knowing if a transaction involving a special measure country/entity occurs. Special Measures are covered in the FFIEC BSA Manual.

First published on BankersOnline.com 10/05/09