BSA/AML Examiner School - Case Study Oct 2023

• 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:

o Name and address of the recipient; o Account number of the recipient; and o Any other specific identifier of the recipient.

• Either the name and address or the numerical identifier of the transmitter's financial institution. Intermediary financial institutions must pass on all of the information received from a transmitter's financial institution or the preceding financial institution, but they have no duty to obtain information not provided by the transmitter's financial institution or the preceding financial institution. Responsibilities of Beneficiary's Banks When our Bank acts as the beneficiary's bank, it is the bank identified in a payment order as the account of the beneficiary, the person to be paid under the transfer order, is to be credited pursuant to the order or otherwise is to make payment to the beneficiary. If the beneficiary is an established customer of the beneficiary bank, you must retain either the original or a microfilm or electronic record of the payment. Generally, since it usually is a deposit to an account, your normal recordkeeping rules cover this. Recordkeeping Requirements for Incoming Wires For each payment order of $3,000 or more that the Bank accepts as a beneficiary's bank, the Bank must retain a record of the payment order. Customer Address The Travel Rule allows the use of physical mailing addresses only. Post office boxes can be used as an alternate address for mailing purposes, as long as the institution maintains the transmitter's physical address on file. OFAC Compliance The customer identification program (CIP) procedures in the BSA now require the Bank to verify all new customers against the lists published by the Office of Foreign Assets Control (OFAC). It is against the law to do business with or for any person or entity on the list, and you can't know who that is unless you verify transactions. The Best Practice is to verify each of the parties to each outgoing and incoming wire against the OFAC list. This means you check the name of your customer, his customer, and the ultimate beneficiary bank. XIV. Information Sharing – USA PATRIOT Act Policy and Procedures Section 314(a) Requests for Records — Information Sharing between Law Enforcement FinCEN posts section 314(a) subject lists through their FinCEN secure website. Every two weeks, or more frequently it an emergency request is transmitted, the Bank's designated point(s) of contact as the BSA Officer will receive notification from FinCEN via email that there are new postings to FinCEN's secure website. The point of contact will be able to access the current section 314(a) subject list (and one prior) and download the files into our System for searching. The Bank is required to report all positive

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