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Best Practice Recommendations

Wire Transaction Monitor

Revised December 6, 2015

Copyrighted by Wayne Barnett Software, a Texas Corporation

Disclaimer of Liability

Disclaimer of liability: We’re often asked for Best Practices in using or software. Unfortunately when it comes to detecting money laundering, fraud, identity theft, financial abuse of the elderly and other nefarious activity, there isn’t one strategy that works for all financial institutions. However, based on our years of experience, we do offer the following recommendations as a starting point.

Very important note: Please understand that the procedures we recommend in this document may be different from what we recommended in previous documents. We update our Best Practice Guides (BPG) periodically, to reflect what is current in the banking and credit union industries. The bad guys are always doing new things—and these guides help you stay one step ahead!

This copyrighted document is owned by Wayne Barnett Software (WBS), a Texas Corporation. It is intended solely for the use of WBS current and prospective customers. Any distribution of this document by anyone other than Wayne Barnett Software is prohibited.

WTM Best Practice Guide, copyrighted by Wayne Barnett Software, a Texas Corporation

Table of Contents

ContentsWTM Dashboard.........................................................................................................................................1

Daily Best Practice 1: Import the Wire Files into WTM................................................................................2

Daily Best Practice 2: Review the Daily Wires for Completeness.................................................................4

Daily Best Practice 3: Check Incoming and Outgoing Wires for OFAC Compliance......................................7

Daily Best Practice 4: Update OFAC Files...................................................................................................10

Daily Best Practice 5: Check Customer Names for OFAC Compliance........................................................12

Bi-Weekly Best Practice 1: Update the CIF................................................................................................16

Bi-Weekly Best Practice 2: Update Risk Ratings.........................................................................................18

Bi-Weekly Best Practice 3: Check Wires Against 314(a) List......................................................................19

Monthly Best Practice 1: Monthly Wire Report Review............................................................................22

Monthly Best Practice 2: Monthly Wire Report Review for Account Relationships...................................25


Dashboard

WTM Dashboard

Dashboard.png

Very important note: The WTM dashboard is referenced in several parts of the Best Practice Guide (BPG). To save space, we will only display one copy of the dashboard.

Dashboard panels 1 – 4 are the top row, going left to right.

Dashboard panels 5 – 7 are the bottom row, going left to right.


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Daily Best Practice 1—Import the Daily Wire Files into WTM

Daily Best Practice 1: Import the Wire Files into WTM

You can import the daily wire files through the dashboard, by clicking anywhere within the “X” and “Y” axis area in dashboard panel 1.

Dbpanel1

1. If I was importing a file for the 29th, I’d click in the white area above the number 29, located on the far right of the “X axis”. (I hate to write the words “X axis” and “Y axis”, as it brings back stressful memories of Mr. Sanchez and my high school geometry class.)

2. The screen below will appear; in most cases you’ll just click Continue.

Allitemsimport

3. The screen below will appear. The default date is the prior business date. You can change the date, if necessary.


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Daily Best Practice 1—Import the Daily Wire Files into WTM

Importfiles

4. Click Continue, navigate to the file and double-click on the one you want to import.

Importfilesselect

Very important note: The circle in dashboard panel 1 shows a number, and below the circle are the words “Missing Files”. The number in the circle shows how many “anticipated file imports” were skipped in the past 30 days.

Click on the circle and WTM will display the “Processing Recap Report” for the past 30 days. Look for the words “Missing”, “Partial” or “Not Imported” to see the day where the anticipated file was not imported.

Auditprorecapresults


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Daily Best Practice 2—Review the Daily Wires for Completeness

Daily Best Practice 2: Review the Daily Wires for Completeness

Banks in the US are required by law (31 CFR 1010.410) to obtain and keep certain information for all wire transfers of $3,000 or more. The information that must be obtained & kept includes the name, address and account number of both parties (that is, the originator and the beneficiary). Banks must also retain the date of the wire, the amount and any special instructions stipulated by the originator and/or the originating bank. 31CFR 1010.410 is often referred to as the “Travel Rule”.

If the originating bank violates the law and sends a wire that is missing required information, the receiving bank can accept or refuse the wire (refusals almost never happen). If the receiving bank accepts the wire, it is not required to contact the originating bank, to try and obtain the missing information—but it can if it wants too. Likewise, the receiving bank can notify the sending bank of a conditional acceptance, pending receipt of the missing information. (Conditional acceptances are becoming more common, especially when the receiving party has been identified as a high-risk customer.)

Bottom line: you can’t be cited for a violation of law, when it was the originating bank that failed to obey the Travel Rule. But, it is incumbent upon management to show that all information presented was retained—and that’s where WTM is extremely beneficial: when a wire arrives from Fed, it can have up to approximately 300 data fields. WTM retains every data field for every wire, regardless of the dollar amount.

Very important note: you may be wondering if you have to keep Travel Rule data for wires below $3,000; the answer is no. However, the U.S. is the only country in the G20 group of nations that doesn’t require monitoring of all wire—and this bugs the bejeebers out of the regulators. So, if you aren’t keeping data on all wires, you can bet the regulators will recommend that you do so. They will justify their recommendation by explaining it will help the bank to better spot suspicious activity.

1. Review the Daily Wire Report, to ensure all wires for the day are accounted for. Dashboard panel 5 (lower level, first panel on the left) has links to the four most-used wire reports. Please click on the first report (Report #101). The screen below will appear.


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Viewall

Click Continue to see the wires imported into the system.

Viewallscreendetail

The bottom of this report shows the total amount for incoming and outgoing wires. You should verify that the totals on this report match the totals provided by Fed or Bankers Bank.

If the incoming and outgoing totals in WTM do not match the totals from Fed or Bankers Bank, you need to document the reason for the discrepancy. (Such discrepancies almost never happen). We recommend you create a dossier in DiCK, to document the discrepancy.

Important note #2: All of the columns on the screen are click-through columns. Some of the more common click-thru tasks are listed below. (Note: in some instances, you must have specific authority to perform the click-thru task.)

i. Clicking on the Account Number will let you see all wires posted to that account number.


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ii. Clicking on an originator or beneficiary name will let you see all wires with that originator or beneficiary name.

iii. Clicking on the Transaction Type will let you edit some of the information for that wire (for example, account number, name, beneficiary ID, originator ID, foreign wire identifier, etc.).All changes are logged and the logs are kept forever.

iv. Clicking on the Amount will let you see all details for the wire.

v. Clicking on the Risk Rating column will let you assign a risk-rating to this account.


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Daily Best Practice 3—Check Incoming and Outgoing Wires for OFAC Compliance

Daily Best Practice 3: Check Incoming and Outgoing Wires for OFAC Compliance

There is no law that says you have to check the OFAC Specially Designated National (SDN) list, prior to opening an account or doing a transaction. Likewise, there’s no law that says you have to routinely check your existing customers against the SDN list. Yes ma’am and yes sir—you read that correctly: there is no law that says you have to do these things.

But, there is a law that says you can’t do business with anyone on the OFAC SDN list.

So, if your bank doesn’t check new accounts and third-party transactions against the list, you are operating fool heartedly.

What are the fines for OFAC violations? At a minimum, it’s the amount of the transaction. So, if you cash a check that is payable to someone that’s on the SDN list, you will have to pay OFAC a penalty that’s equal to the amount of the check. You will also have to pay a fine, the amount of which is usually $2,000 - $3,000 (assuming it’s just your first or second OFAC fine.) The fine’s increase dramatically after the first couple of violations. Also, criminal prosecution and jail time has occurred at banks where the number of OFAC violations was egregious. (We’ve seen BSA officers, president and CEOs prosecuted for willful blindness, when it comes to OFAC violations).

You may be wondering what are the most common transactions attempted by folks on the SDN list. The answer:

1) Cashing of a check, made payable to someone on the SDN list.

2) Incoming IAT transactions (both debits and credits)

3) Receipt of a wire, where the wire originator is on the SDN list, or, delivery of a wire where the beneficiary is on the SDN list.

WTM and OFAC-It! can help you with #1, but that really isn’t the focus of this BPG; please call us at 877-945-4344 if you want to discuss this further.

SAM has you covered with #2; please review the Best Practices Guide for SAM-ACH for more information on this topic.

WTM has you covered for #3; we’ll discuss how this feature works below.

1. Dashboard panel 4 (upper level, last panel on the right) lets you do OFAC checks on all incoming and outgoing wires, and, on your entire customer database.


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Dbpanel2

Click on the lower circle to perform an OFAC check on your incoming and outgoing wires; the screen below appears.

Ofacfilecheck

Click Continue to review the report.

Ofacfilecheckscreen

Click on the far-right column to identify any name that you consider an OFAC match.

Very important note: We only check names that are not the bank’s customers. So, for outgoing wires we check:

1) Receiving bank name2) Beneficiary name3) Intermediary receiving financial institution

For incoming wires we check:

1) Sending bank name


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2) Originator name3) Instructing financial institution name

Why don’t we check your customer’s names? It’s because we don’t want any confusion. If you see a name on this list that may be a match, you need to investigate it. We don’t want you saying “Oh yes, Mohammed Jones is our customer,” when in fact this is a different Mohammed Jones.


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Daily Best Practice 4—Update OFAC Files

Daily Best Practice 4: Update OFAC Files

OFAC updates happen at the discretion of OFAC. We’ve seen OFAC release updates 12 days in a row. We’ve also seen intervals of 22 days between updates. And in very rare instances, we’ve seen two updates in one day.

So, you will not perform this Daily Best Practice every day.

On those rare occasions (1 – 2 times a year) where two updates occur, the second update will include the first update’s revisions. So if you were slow to run the first import, you can skip it and just run the second. But if you were Johnny-on-the-spot with the first update, you’ll have to import the second update too.

We will advise you via e-mail when OFAC updates the SDN list. You can also sign-up for updates from OFAC. Both the updates from us and the updates from OFAC have links for you to use, to download the files.

1. Dashboard panel 3 (upper level, second panel from the right) shows the number of days since you last updated your OFAC files. It also shows the date of the files.

Dbpanel3

2. At this time, we don’t have a link on the dashboard to our download site. However, you can bookmark the link below to be taken to it.

www.barnettsoftware.com/downloads-private

3. After downloading the three OFAC files (Primary SDN, Alternate SDN and SDN Address), you must import them into the WTM database. To import the files, click on one of the checkboxes that’s to the immediate left-of each file name. (It doesn’t matter which checkbox you choose.) The screen shown below will appear


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http://www.barnettsoftware.com/downloads-private

Daily Best Practice 4—Update OFAC Files

Ofacfileimport

Select the file you want to import, click Continue and navigate to where the file is stored.

Again, please remember that you must import all three files. The system will show you which files have been imported.

Very important note: Let us say it again please: each file is cumulative. So, if new files come out on Monday and Tuesday, and on Wednesday you realize you didn’t import either one, all you need do is import the file from Tuesday.


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Daily Best Practice 5—Check Customer Names for OFAC Compliance

Daily Best Practice 5: Check Customer Names for OFAC Compliance

As previously noted, there is no law that says you have to check the OFAC Specially Designated National (SDN) list, prior to opening an account or doing a transaction. Likewise, there’s no law that says you have to routinely check your existing customers against the SDN list.

But, there is a law that says you can’t do business with anyone on the OFAC SDN list. So, it’s a wise idea to check your customers against new and changed OFAC data.

And that statement leads to our next question: what customer names do you include, when you do an OFAC check? With WTM, you have two choices:

1) Create a list of all customer names, in a .txt file. The folks that use this procedure want to include all or some of the following:

i. Safe deposit box customers ii. Account co-owners iii. Non-customer signors on DDA accountsiv. Non-customer beneficiaries on CDs v. Non-customer loan guarantors

2) Just check the primary account owner of all accounts, which is the same names we have in the WTM CIF database. The folks that use this procedure have an OFAC strategy that includes the following:

i. Safe deposit boxes are only rented to deposit or loan customers.ii. If an account co-owner or authorized signor was an OFAC SDN, the bank would

remove them from the account—but they would not have to freeze the account. (Note: this is a gray area in OFAC rules. As long as the SDN was not on the OFAC list when the account was open, this strategy is probably correct.)

iii. All CD beneficiaries are checked for OFAC compliance, prior to any funds being disbursed.

iv. All guarantors are checked for OFAC compliance, prior to any demand for funds being issued or accepted.

Which of the two customer lists is best? We think #2 is. It’s easier to maintain and more likely to be kept up-to-date. But, we give you both options so that you can decide what’s best for your bank.

1. Dashboard panel 4 (upper level, last panel on the right) lets you do OFAC checks on all incoming wires, and, on your entire customer database. This Best Practice focuses on the entire customer database.


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Dbpanel2

Click on the upper circle to check to perform an OFAC on your entire customer database; the screen below appears.

Ofaccheckcif

An explanation of the key data fields is presented below.

1) Field #2. Number of prior days OFAC data to include – the default value is 30. This field tells the system to use all OFAC additions and changes from the past 30 days. If you always do an OFAC check after every update—and you’re sure this is the case—you can set this value at 1.

2) Field #4. The tolerance level – we recommend 15. This tells the system how similar names have to be, to be considered a possible match. The lower the number, the more exact the match has to be. (For example, a tolerance level of 50 will produce more possible matches than a tolerance level of 10.)

You are probably wondering why we don’t set this value at a really low number (like 3 or 5). The reason: OFAC does not forgive spelling errors. Let’s use an example where you have a customer name John Smith but you enter it as Jon Smith. If OFAC adds the name John Smith to its list and you have a tolerance level of 5, the name Jon Smith will not be presented as a possible match. However, with a tolerance level of 15, Jon Smith will be flagged as a possible match for John Smith.


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3) Field #5. The number of starting letters to use – we recommend 7. We check all names at least twice (last name/first name & first name/last name). To help eliminate false positives, we say “OK, either the first 7 letters of the last name or the first name have to match the OFAC name, before any other OFAC checking is performed.

You are probably wondering why we don’t set this value at a higher number (like 9 or higher). The reason: same as above; OFAC does not forgive spelling errors (and it’s real easy to transpose letters in some Asian and Arabic names).

Click Continue; the screen below appears.

Ofaccheckcifquestion

Click Yes or No, depending on what you want to do.

If you click No, you’ll have to navigate to a file that has a list of names.

Wait for the system to tell you the check is complete, and review the results.

Click on the far-right column for any name that you believe is an OFAC match.

Ofacfilechecksreen2

Very important note: If you are going to use the CIF database for your OFAC checks, you should update it immediately before running the check.

Likewise, if you are going to use a customer list, you should create a new list prior to doing each OFAC check.

Very important note #2: Our OFAC-check strategy is predicated on our understanding that your bank checks all new accounts at the time of opening. If that’s true, we see no need to check them every time, against names that haven’t changed since the initial check.


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Our OFAC-check strategy is unique in the industry: we only check your customers against the additions and updates that are in the current OFAC files. With our strategy, OFAC checks run quickly, false positives are greatly reduced and inadvertent errors are almost eliminated.

However, if your bank finds our OFAC-check strategy to be too progressive, you have the option to check all customer names against the entire OFAC list, every time. You can do this by clicking on field #3. Click here to run the customer check against the entire OFAC database.

Just please be advised we’ll run as slow as all the other OFAC systems and there will be dozens of false-positive results.


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Bi-Weekly Best Practice 1—Update the CIF

Bi-Weekly Best Practice 1: Update the CIF

The Customer Information File (CIF) is a key part of the system. In WTM it is critical for an accurate OFAC check against your customer database. The CIF also builds relationships (which are a key part of the risk rating process).

The CIF should be updated every two weeks, or, just before performing an OFAC check on your customers. The CIF panel on the dashboard will be show a green circle, when the CIF was updated in the prior 0-14 days. It will show a yellow circle when the CIF was last updated 15-28 days ago, and red circle starting on day 29.

Please remember that red on the dashboard is never a good thing.

1. Dashboard panel 2 (upper level, second panel from the left) has a circle that shows the number of days since you last updated your CIF.

Ciflastupdate

2. Clicking on the circle will produce the screen shown below.

Cifimportfile

3. Clicking continue will take you to a file navigation screen; navigate to the file that has a list of name and double-click on it. The file will import and tell you the CIF update is complete.


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Bi-Weekly Best Practice 1—Update the CIF

The CIF update works with records that are new or recently changed. The system automatically calculates the number of prior days to include in the update.

Very important note: Running the CIF update in one system will result in all systems being updated.

Very important note #2: On rare occasions, you may want to do a full CIF refresh. You can do this by entering 999 in the number of prior days.


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Bi-Weekly Best Practice 2—Update Risk Ratings

Bi-Weekly Best Practice 2: Update Risk Ratings

When a risk-analysis is performed on a customer, a risk-review date is automatically assigned by the system. The review date is based on the overall risk-score; it can be revised by the person doing the risk analysis.

Dashboard panel 6 (bottom row, middle panel) advises you as to when it’s time to do a follow-up risk analysis.

Riskratingsdue

Clicking on the colored bar will display a list of the accounts that are due for review.

Very Important Note: You can archive risk ratings that were done for accounts that subsequently closed. Please see the WTM User Guide for instructions on archiving risk ratings for closed accounts. (Or, call Wayne at 877-945-4344; he’s a fun guy to talk to and we’re always glad to hear from our customers!)


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Bi-Weekly Best Practice 3—Check Wires Against 314(a) List

Bi-Weekly Best Practice 3: Check Wires Against 314(a) List

FinCEN releases its 314(a) list every two weeks. On occasion, it also produces an interim list.

What is the 314(a) list? It’s a list of people and businesses that law enforcement officials have an interest in. The people and businesses on the list have not been charged with a crime and there’s no prohibition against doing business with them.

What are your responsibilities, in regards to checking the 314(a) lists? Well ma’am and sir, you have two:

1) The list has to be downloaded from FinCEN’s web site, within 24 hours of being made available.

2) You have to complete your check of the list within fourteen calendar days of the file release date, unless FinCEN stipulates differently. (On rare occasion, FinCEN has instructed banks to complete the check in as little as three days.)

Most banks don’t check their wire log against the 314(a) list. The reason for this? They say that wires are only done for customers, so there’s no need to do a separate check of the wire log.

Is this strategy a sound one? Well ma’am and sir, it depends: if the compliance officer is correct and wires are only done for customers, this strategy is 100% sound. But … if one wire was done for a non-customer (for example, the mother of the bank’s best customer), and that person wasn’t included in subsequent 314(a) checks, you will have a series of incomplete checks—and each incomplete check is a violation of law. Accordingly, one wire done for a non-customer could create 26+ violations of law.

Will the regulators cite you for this violation of law? Probably not … but they can if they want too. And if they do cite a violation of law, they are required to issue a Cease and Desist (C&D) Order.

As we all know, C&Ds are public records—and greatly embarrassing. They can also result in fines, a lower exam rating and a more frequent exam schedule. So, all things considered, we recommend you take 60 – 90 seconds every two weeks, to check your wire log against the 314(a) list.

1. Dashboard panel 7 (lower level, far right) has two circles: one represents the 314(a) business file; the other represents the 314(a) consumer file.


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Dbpanel7

The number in each circle represents the number of days since the last 314(a) check was completed.

Click on the “business circle” to check the wire log against the 314(a) business file.

Click on the “consumer circle” to check the wire log against the 314(a) consumer file.

Cifimportfile

2. Enter the dates stipulated by FinCEN.

The normal date range for wires is six months. On occasion, FinCEN may specify a longer date range.

3. Enter the tolerance level and the number of starting letters for the name. We recommend 15 and 7, respectively.

Please see Daily Best Practice 5: Check Customer Names for OFAC Compliance on page 12 for a description of tolerance level and number of starting letters fields.

4. Review the results.


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Very Important Note: When WTM does a 314(a) check of the wire log, it checks both your bank’s customer and the other bank’s customer. There’s no legal requirement to check the beneficiary on an outgoing wire, or, the originator on an incoming wire. But, in 2003, FinCEN asked vendors to design their systems to check both parties (and we’ve done so ever since).

If you find a match on the other bank’s customer, you’re under no legal obligation to report it—but we recommend you do so. FinCEN will appreciate it and they’ll send you a nice thankyou letter for doing so.


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Monthly Best Practice 1—Monthly Wire Report Review

Monthly Best Practice 1: Monthly Wire Report Review

We’ve already discussed the need to review the daily wire report (please reference Daily Best Practice 2:Review the Daily Wires for Completeness on page 4.) Now we’re going to talk about the Monthly Wire Review.

There’s really just one reason to review the monthly wire report: to find customers that have a large dollar-amount of wires.

Why do we care about a large dollar amounts of wires? Two words: immediate availability.

Why do we care about immediate availability? Two reasons:

1) It’s highly unusual for consumer accounts to have a need to make funds immediately available to third parties. The most common reasons are buying a house, buying a very expensive car or boat, or, moving money to an investment account.

None of these events are common or recurring. In fact, recurring wire activity with a consumer account could indicate wire fraud or money laundering.

2) Terrorist financing could be involved, especially with international wires.

In this day and age, when money is moved to terrorist groups, it usually done through phony PayPal transactions and IATs. (That’s how the terrorist in the 2015 French attack received the money to fund their operations.) But wires are still used, for the simple reason that large sums of money ($20,000+) can be made immediately available (and with IATs, it can take 3+ days).

What do we mean by “a large dollar amount”? That depends on the type of account.

For personal accounts, we recommend you consider aggregate totals of $20,000 or more as large.

For commercial accounts, we recommend you consider aggregate totals of $50,000 or more as large.

Of course, these are just our suggestions; you can use any amount you want. But, to keep the regulators happy, whatever amount you choose needs to correspond to the “high wire amounts” that your bank uses in the auto-calc risk-rating procedures.

1. Dashboard panel 5 (lower level, first panel on the left) has links to the four most-used wire reports. Please click on the third report (Report #301). The screen below will appear.


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Viewallmoselect

The starting and ending dates will normally span one calendar month.

We recommend the following parm settings:

3. Minimum amount: $20,000 for personal accounts, $50,000 for commercial accounts.

The system will ask if you just want summary information. This is a personal choice. If you click no, the system will show you limited information about each wire sent-to or sent-from the customer’s account

Viewallmoselectjustsummary

In most cases, I personally like to see the details. It lets me quickly see who sent money to the customer, or, who he/she sent money to. But, again, this is a personal preference.

Review the results. (This one shows only summary information.)

Viewallmoselectscreen


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Or, review the results with details. (This one shows detail information.)

Viewallmoselectscreenwithdetails

For a bank with $500 million in assets, the report will normally show 10-15 entries. (Please adjust the anticipated number of entries at your bank, based on your asset size.)

Every customer on this report should be investigated, with special attention given to those who have multiple transactions or single transactions in multiple accounts.

Every customer on this report should also be risk-rated.

If there are international transactions to a foreign business, it may behoove the bank to do a Google search on the foreign business. If there is any hint of the wire recipient being involved in terrorist financing, money laundering, drug dealing, arms dealing, human slavery or other illegal activity, a SAR should be field.

And, of course, make sure all outgoing wires are check for OFAC compliance

Very Important Note: There’s been a few times where banks that weren’t our customer contacted us, to ask our advice on handling an after-the-fact OFAC violation. The answer is simple: contact OFAC. You will, without question, have to forfeit funds to OFAC equal to the amount of the wire. But, assuming it has not happened before, it’s unlikely that penalties will be assessed.


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Monthly Best Practice 2—Monthly Wire Report Review for Account Relationships

Monthly Best Practice 2: Monthly Wire Report Review for Account Relationships

Everything we discussed in Monthly Best Practice 1: Monthly Wire Report Review on page 22 applies to this best practice too. But here, we take it one step further.

Suppose the customers that are trying to launder money or fund terrorist operations are husband and wife, and they are using their separate accounts to transfer money. This is not a common situation, but it’s not unheard of.

With this last best practice, we look at related accounts.

1. Dashboard panel 5 (lower level, first panel on the left) has links to the four most-used wire reports. Please click on the fourth report (Report #401). The screen below will appear.

Viewallmosrelelect

The starting and ending dates will normally span one calendar month.

We recommend the following parm settings:

3. Minimum amount: $20,000 for personal accounts, $50,000 for commercial accounts.

5.Minimum number of transactions: 2


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Monthly Best Practice 2—Monthly Wire Report Review for Account Relationships

The system will ask if you just want summary information. This is a personal choice. If you click no, the system will show you limited information about each wire sent-to or sent-from the customer’s account.

Viewallmoselectjustsummary

In most cases, I personally like to see the details. It lets me quickly see who sent money to the customer, or, who he/she sent money to. But, again, this is a personal preference.

Review the results. (This one shows only summary information.)

Viewallmorelselectscreen

Or, review the results with details. (This one shows detail information.)

Viewallmorelselectscreenwithdetails

For a bank with $500 million in assets, the report will normally show 6-9 entries. (Please adjust the anticipated number of entries at your bank, based on your asset size.)

Every customer on this report should be investigated.

Every customer on this report should also be risk-rated.

If there are international transactions to a foreign business, it may behoove the bank to do a Google search on the foreign business. If there is any hint of the wire recipient being involved in terrorist financing, money laundering, drug dealing, arms dealing, human slavery or other illegal activity, a SAR should be field.

And, of course, make sure all outgoing wires are check for OFAC compliance


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Thank you for using Wayne Barnett Software

Thank you for being our customer, we appreciate you. If you have any questions about this guide, or, ideas for improvements, please let us know. Your e-mails and phone calls are always appreciated.

[email protected]

877-945-4344


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mailto:[email protected]

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