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Is a wire transfer sent to Puerto Rico considered a domestic or an international funds transfer? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Is a wire transfer sent to Puerto Rico considered a domestic or an international funds transfer?

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For Bank Secrecy Act/Anti-Money Laundering (BSA/AML) purposes, a wire transfer to a person in Puerto Rico is treated as a domestic funds transfer. The BSA/AML regulations define the term “United States” to include Puerto Rico.

For resources related to our guidance, please see:

  • FinCEN BSA/AML regulations, 31 CFR 1010.100(o) (“Domestic. When used herein, refers to the doing of business within the United States, and limits the applicability of the provision where it appears to the performance by such institutions or agencies of functions within the United States.”)
  • FinCEN BSA/AML regulations, 31 CFR 1010.100(hhh) (“United States. The States of the United States, the District of Columbia, the Indian lands . . . and the Territories and Insular Possessions of the United States.”)
  • FinCEN BSA/AML regulations, 31 CFR 1010.100(zz) (“Territories and Insular Possessions. The Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, the Commonwealth of the Northern Mariana Islands, and all other territories and possessions of the United States other than the Indian lands and the District of Columbia.”)