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InfoSight Highlight: Wire Transfers/Transportation of Currency
Friday, January 27, 2017 6:45 AM

The Bank Secrecy Act requires credit unions to collect and retain certain information in connection with funds transfers of $3,000 or more. The term “funds transfers” generally refers to wire transfers.

The BSA’s “Travel Rule” requires a credit union to include certain information in payment orders relating to transmittals of funds (mostly wires) of $3,000 or more, whether or not currency is involved. In other words, certain information must “travel” with the wire. Funds transfers governed by Regulation E or the Automated Clearing House rules are not covered by the Travel Rule.

Note: NACHA ACH rules require all international payments made via the ACH Network to be identified as International ACH Transactions using the Standard Entry Class (SEC) Code – IAT. The rules also require that all IAT payments include the specific data elements defined by the BSA’s “Travel Rule.”

Under the Travel Rule, all “transmittor’s financial institutions” (generally speaking, the originating financial institution) must include and send the following in the transmittal order:

  • The transmittor’s name, account number, and address;
  • The identity of the transmittor’s financial institution;
  • The amount of the transmittal order;
  • The execution date of the transmittal order; and
  • The identity of the recipient’s financial institution.

If received, the transmittor’s financial institution must also include the name, address, account number and any other specific identifier of the recipient. In addition, an intermediary financial institution must pass on all of the information it receives from a transmittor’s financial institution or the preceding intermediary financial institution.

Source:  InfoSight Compliance.

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