Wire Transfer Guidance
The amendments to the Anti-Money Laundering and Countering Financing of Terrorism (Requirements and Compliance) Regulations 2011, effective 1 June 2024, introduce new requirements for wire transfers involving ordering, intermediary, and beneficiary institutions. The AML/CFT supervisors have issued guidance on these new requirements, which are summarised below.
As an ordering institution, you must ensure international wire transfers under $1,000 include the originator’s name, account or identifying information, and the beneficiary’s name and account/reference number. You do not need to verify the originator’s name unless there are grounds to report a suspicious activity. Moreover, for international wire transfers, you must maintain records of the beneficiary’s name and account/reference number for five years after the end of the business relationship or from the transaction date (in the case of an occasional transaction).
As an intermediary institution, you must retain all information accompanying a wire transfer when forwarding it to another intermediary institution or a beneficiary institution. If you are unable to do so due to technical reasons, you must keep a record of the information for five years. Moreover, you are required to include in your AML/CFT compliance programme policies, procedures and controls to identify and manage international wire transfers lacking originator or beneficiary information.
As a beneficiary institution, you are required to include in your AML/CFT compliance programme policies, procedures and controls to identify and manage international wire transfers lacking originator or beneficiary information.
Reach out if you would like assistance in implementing these regulations effectively.
