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  • FC-3.1 FC-3.1 Electronic transfers

    • Outward Transfers

      • FC-3.1.1

        Conventional bank licensees must include all required originator information details with the accompanying electronic transfers of funds they make on behalf of their customers. Non-routine transfers must not be batched, if batching increases the risks of money laundering or terrorist financing. This obligation does not apply where the transfer is made by a bank acting as principal or acting on behalf of another bank as principal such as in the case of payment of spot FX transactions.

      • FC-3.1.2

        For the purposes of this Chapter, "Originator Information" means:

        a) The name of the payer;
        b) The address of the payer; and
        c) The account number of the payer (where funds are being remitted from an account with your bank).

      • FC-3.1.3

        It is not necessary for the recipient institution to pass the originator information on to the payee. The obligation is discharged simply by notifying the recipient institution of the originator information at the time the transfer is made.

    • Inward Transfers

      • FC-3.1.4

        Banks must:

        a) Maintain records (in accordance with Chapter FC-7 of this Module) of all originator information received with an inward transfer; and
        b) Carefully scrutinise inward transfers which do not contain originator information (i.e. full name, address and account number or a unique customer identification number). Licensees must presume that such transfers are "suspicious transactions" and pass them to the MLRO for review for determination as to possible filing of an STR, unless (a), the sending institution is able to promptly (i.e. within two business days) advise the licensee in writing of the originator information upon the licensee's request; or (b) the sending institution and the licensee are acting on their own behalf (as principals).