Missing originator or beneficiary information

Automated and manual transaction monitoring shall identify unusual or suspicious activity using risk-based scenarios and thresholds.

Banks must collect, retain, and transmit certain information relating to funds transfers of $3,000 or more, including originator name, address, account number, and amount (31 CFR 1010.410(e)).

Financial institutions may not keep anonymous accounts or accounts in obviously fictitious names and must, by a principle set out in law, undertake customer due diligence when establishing a business relationship, carrying out an occasional transaction above USD or EUR 15,000 or a payment or value transfer covered by INR.16, when money laundering or terrorist financing is suspected, or when they doubt previously obtained identification data: identify and verify the customer from reliable independent sources; identify the beneficial owner and take reasonable measures to verify that identity, understanding the ownership and control structure of legal persons and arrangements; understand and where appropriate obtain information on the purpose and intended nature of the relationship; and conduct ongoing due diligence and transaction scrutiny consistent with the customer's profile including, where necessary, the source of funds. The extent of each measure follows a risk-based approach; verification takes place before or during establishment of the relationship, or as soon as reasonably practicable after it where risks are managed and business would otherwise be interrupted; an institution that cannot complete CDD does not open the account or perform the transaction, or terminates the relationship, and considers a suspicious transaction report; the requirements apply to new customers and, on materiality and risk, to existing ones. The Interpretive Note sets the risk-based approach, enhanced and simplified measures, the specific measures for legal persons, arrangements and beneficiaries of life insurance, reliance on prior verification and the timing rules.

Countries ensure that financial institutions include required and accurate originator information and required beneficiary information on payments or value transfers and related messages, structured to the extent possible and remaining with the transfer throughout the payment chain; monitor transfers to detect those lacking required information and take appropriate measures; and, in processing transfers, take freezing action and do not conduct transactions with persons and entities designated under the UN Security Council resolutions on terrorism and proliferation financing. The Interpretive Note, revised in June 2025 with implementation expected by the end of 2030, sets the information requirements and de minimis thresholds, the exemptions, and the duties of ordering, intermediary and beneficiary institutions and MVTS providers; it is modelled paragraph by paragraph as the separate framework FATF Recommendation 16 - Payment Transparency (Travel Rule).

Financial institutions monitor payments or value transfers to detect those lacking required originator or beneficiary information and take appropriate measures, which the Interpretive Note specifies for intermediary and beneficiary institutions as reasonable detection measures and risk-based execute, reject or suspend decisions.

Cross-border transfers above the applicable threshold always carry the names of originator and beneficiary; their account numbers where used, or a unique transaction reference number, with the funding institution's name and account where funds are drawn elsewhere; the originator's address (country and town suffice where no standardised postal address exists) and the beneficiary's country and town or nearest alternative; the originator's date of birth where a natural person (year of birth where the full date is unavailable); and, for a legal person originator or beneficiary, the connected BIC, the Legal Entity Identifier or the unique official identifier where one exists.

The ordering institution ensures that cross-border transfers above the de minimis threshold contain required and accurate originator information (verified for accuracy) and required beneficiary information.

An intermediary institution takes reasonable measures, consistent with straight-through processing, to identify cross-border transfers that lack required originator or beneficiary information.

A beneficiary institution takes reasonable measures, which may include post-event monitoring or real-time monitoring where feasible, to identify cross-border transfers that lack required originator or beneficiary information.

Systems and controls for monitoring customer transactions for unusual or suspicious activity.

Records relating to electronic funds transfers must be maintained under s 114.

Transfer instructions for funds of any value sent out of Australia must be reported within 10 business days.