ISO20022 vs. The Travel Rule... Which Applies?

The recent implementation of the ISO20022, required by the Federal Reserve, created a whirlwind of confusion. The ultimate benefits for banks will reduce errors, require less manual work, improve compliance, create better cash flow forecasting, and enhance customer service.  You must remain diligent regarding the input of “required data”.

When discussions about “ISO requirements” take place, bear in mind those requirements merely address the minimum information required by the program to successfully transmit the wire transfer. The Travel Rule requirements are in place for a totally different purpose; they, serve to assist in combatting global terrorism and money laundering.

The Travel Rule requires the following:

• The name of the transmitter

• The account number of the transmitter, if used

• The address of the transmitter

• The identity of the transmitter’s financial institution

• The amount of the transmittal order

• The execution date of the transmittal order

• The identity of the recipient’s financial institution

IF RECEIVED, the wire transmission should provide:

• The name of the recipient

• The address of the recipient

• The account number of the recipient

• Any other specific identifier of the recipient

The ISO requirements were not intended to, and should never supersede the requirement for the Travel Rule. The banks’ default decision should be to abide by the law.