ITG FAQ #3 Answer-What are the recordkeeping requirements for money transmitters?
Copies of all filed Currency Transaction Reports (CTRs) must be retained by the financial institution for five years from the date of the report (31 CFR 103.27(a)(3)). Certain records are required to be retained for fund transfers (wires) of $3,000 or more, sent or received by, or for, an individual on any one business day (31 CFR 103.33).
A. The following information must be obtained for the records:
- The transmitter’s name and address
- The amount of the transmittal order
- The execution date of the transmittal order
- Any payment instructions received from the transmitter
- The identity of the recipient’s financial institution
- Any form relating to the transaction that is completed or signed by the person placing the order
- Any of the following items received with the transmittal order:
o The name and address of the recipient
o The account number of the recipient
o Any other specific identifier of the recipient
B. If the transmitter is not an established customer, the following records also must be retained:
- Verification of the transmitter’s name and address
- The type and number of identification reviewed (e.g., driver’s license)
- The transmitter’s taxpayer identification number i.e., SSN, AIN, passport number and country of issuance
C. For all transmittal orders that it accepts for a recipient, if the recipient is not an established customer, the following records must be retained:
- The original, microfilm, other copy, or electronic record of the transmittal order
- Verification of the recipient’s name and address
- The type and number of the identification reviewed
- The recipient’s taxpayer identification number
D. These records must be retained by the financial institution for five years (31 CFR 103.38(d)).