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Right to Refuse Wire Transfer- Unusual Activity

Answered by: 
Randy Carey
John Burnett

Question: 
Do we as a bank have the right to refuse a wire transfer request if we feel it is suspicious and unusual activity for a particular customer? This customer had a wire come in yesterday and is now requesting an international wire transfer to Nigeria. Of course we know our responsibilities under BSA and the steps we need to take for suspicious activity, but we also would rather simply refuse to conduct the transaction altogether.
Answer: 

by Randy Carey:

You are never under any obligation to conduct a transaction for a customer or non-customer when the bank is not comfortable getting involved.

Answer: 

by John Burnett:

Unless you have a contract with the customer in which you agree to provide the service as requested (which is very rare, and typically only done with commercial accounts), you're certainly able tor refuse this request.

Answer: 

by Ken Golliher:

You allude to your potential SAR filing responsibilities. The SAR narrative will be one paragraph longer if you follow the customer's instructions.

Does that make sense to you?

First published on 11/25/2018

Filed under: 
Compliance
Filed under compliance as: 
Wire Transfers

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