Wire Transfer Authorization

Confirm the person requesting the wire is authorized on the account. For phone requests, use callback verification to a number already on file - never a number the caller provides. For in-person requests, check government-issued ID. Red flags: - Urgency or pressure to skip steps - New beneficiary with vague relationship - Recent email compromise reported - Customer seems coached or nervous If you can't verify identity, do not proceed.

Screen the beneficiary name, bank, and country against OFAC sanctions lists. Per 31 CFR 501.604, you must screen before processing any transfer. Document any potential matches and escalate to BSA Officer if a hit is found. Never proceed with transfers to: - SDN list matches - Sanctioned countries (North Korea, Iran, etc.) - Blocked persons or entities False positives happen - document your determination.

Verify the account has sufficient available funds for the transfer plus any fees. Check for holds, pending transactions, legal restrictions, or account freezes. Also verify: - No recent fraud alerts on the account - Account is in good standing - Wire limits haven't been exceeded - Customer hasn't reported email compromise

For wires over $10,000, obtain dual approval from an authorized second approver. Execute the wire through your wire system and obtain the Federal Reference Number. Document: - Approval chain - Execution timestamp - Fed reference or confirmation number - Any notes or exceptions Notify the customer once the wire is sent.