Education & Training

Question:
If an Originator is creating an IAT entry (including Remittance Addenda and Foreign Correspondent Bank Addenda if necessary) and discovers that it does not have complete names and/or addresses for mandatory fields, can the fields be populated with “Bank Customer” in the customer’s name field and “Not Avail” in the address field? If the Originator does not populate mandatory fields with correct information, what will happen?  

Answer:
No, using terms like "Not Available" or other generic information may cause the Receiving Financial institution to return the transactions.   If the fields are not properly populated and the FI can not perform an OFAC review, the entry may be returned using Return Reason Code R17 File Record Edit Criteria. If the entry is returned using R17, Addenda record #8 (Addenda Type Code 99) field #8 (34 characters) will be used to identify that further information is needed to complete the OFAC compliance review.