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OCC BULLETIN 2004-1
To: Chief Executive Officers and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel

Description: Notice of Expiration of Conditional Exception to BSA Regulations Related to Order for Transmittals of Funds by Financial Institutions

The Financial Crimes Enforcement Network (FinCEN) is giving notice that on July 1, 2004, a conditional exception to a BSA requirement will permanently expire. Upon expiration of that exception, financial institutions will no longer be able to comply with the terms of 31 CFR 103.33(g) by using coded information or pseudonyms for the name of a customer in a funds transmittal order. This notice further explains that FinCEN is revoking prior guidance regarding the meaning of the term "address" in section 103.33(g), eliminating the need to use the conditional exception for transmittal orders lacking a transmitter's street address. The notice was published on December 2, 2003.

Questions may be directed to your OCC supervisory office or the Compliance Division at (202) 874-4428.

Ann F. Jaedicke
Deputy Comptroller for Compliance

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