BSA/AML Examiner School - Case Study Oct 2023

In addition, the following items should be obtained with the wire transfer: • Name and address of the beneficiary/ receiver of the wire; • Account number of the beneficiary; • Any other specific identifier of the beneficiary. Bank Acting as Beneficiary's Bank

For each wire transfer that the Bank accepts as an intermediary bank, or a beneficiary's bank, the Bank must retain a record of the wire transfer. The wire personnel must ensure that all the Travel Rule Requirements are obtained from the bank sending the wire to our Bank. The BSA requires the Bank involved in funds transfers to collect and retain certain information in connection with funds transfers of $3,000 or more. If you suspect, however, that the person is deliberately breaking up the transfer so that it is less than $3,000, you must report it to the BSA Officer as a structuring attempt. The BSA Department will consider filing a SAR. Recordkeeping Procedures for Banks The following recordkeeping requirements apply to fund transfers: Responsibilities of Originator's Banks- Outgoing Wires The originator's bank (us) must record or retain the following information: • Name and address of the originator (our customer) • Amount of payment order • Date of payment order • Payment instructions received from the originator (our customer) with the payment order • Identity of beneficiary's bank — the bank where the beneficiary has the account Name of beneficiary • Address of beneficiary • Account number of beneficiary • Other specific identifiers of beneficiary Travel Rule Requirement for Outgoing Wires For funds transmittals of $3,000 or more, the transmitter's financial institution must include the following information at the time that a transmittal order is sent to a receiving financial institution: • Name of the transmitter, and, if the payment is ordered from an account, the account number of the transmitter; • Address of the transmitter; • Amount of the transmittal order; • Date of the transmittal order; • Identity of the recipient's financial institution • As many of the following items as are received with the transmittal order: (Name and address of the recipient,. Account number of the recipient; and any other specific identifier of the recipient.) • Either the name and address, or the numerical identifier of the transmitter's financial institution. Travel Rule Requirements For funds transmittals of $3,000 or more, the intermediary bank must include the following information received from the sender in a transmittal order at the time that the order is sent to a receiving financial institution: • Name and account number of the transmitter;

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