12/15/2003 Travel Rule to Expire July 2004
Travel Rule Exception to Expire in July; Mailing Addresses Still Accepted
The Financial Crimes Enforcement Network has given notice that the Travel Rule exception to funds transmittal requirements will permanently expire on July 1, 2004. Thereafter, institutions will not be able to use coded information or pseudonyms for the name of a customer in a funds transmittal order. Nevertheless, abbreviated names, names reflecting different accounts of a corporation, trade names, and assumed names of businesses or names of unincorporated divisions or departments of businesses can be used. Industry commenters had objected strenuously to any requirement for giving street addresses instead of mailing addresses, noting that this would require banks to examine each address and compare it with other customer information maintained by the bank, which would often be a manual and expensive process. FinCEN has determined that â€œthe Travel Rule should be read to allow the use of mailing addresses.â€ However, â€œunder no circumstances may a financial institution use its own address or another financial institution's address in place of the customer's address.â€ FinCEN anticipates issuing a new set of frequently asked questions and answers on the funds transfer rules. The notice and subsequent releases will be analyzed in the USA PATRIOT Act Monitor.
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