1057. Are remittance forwarding service providers required to independently verify that a sender’s family or donative remittance is authorized when processing such remittances?
No. Under 31 CFR § 515.572(a)(3), banking institutions, as defined in § 515.314, including U.S.-registered brokers or dealers in securities and U.S.-registered money transmitters, are authorized to provide services in connection with the collection, forwarding, or receipt of remittances authorized pursuant to the CACR, subject to certain conditions. In addition, under § 515.570(h), banking institutions are authorized to unblock and return blocked remittances that would have been authorized under § 515.570(a) or (b). Banking institutions may rely on the statements of their customers that remittance transactions are authorized unless they know or have reason to know a transaction is not authorized. A banking institution is expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and...
1) The diligence-related safe harbor included in this FAQ does not appear in the text of the regulations. See 515.570(h). See section 3(ii) of General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions, Secondary Sanctions and Derivative Designation Contexts (System Ed. Note) for comments on the significance on the last two sentences.