Product: Money transfer, virtual currency, or money service

I received the following question : Question : Are any of the parties involved in this transaction ( or any originators or beneficiaries ) Cuban nationals? 

Response : No. None of the parties involved in this transaction ( or any originators or beneficiaries ) are XXXX nationals. The only parties involved in this transaction ( myself ) and the recipient of the attempted wire transfer are U.S. citizens. The wire transfer in this case was sent to XXXX XXXXXXXX XXXX XXXX  XXXX, Texas - a U.S. financial institution. 


On Monday, XX/XX/year> I requested that Citibank make a domestic wire transfer in the amount of {$1.00}, XXXX to XXXX XXXX at her bank, XXXX XXXX XXXX, XXXX XXXX XXXX, a United States financial institution. My account records show that I have made several wire transfers to XXXX XXXX in the past. The XX/XX/year> wire transfer noted in the " memo '' section that the purpose of the wire transfer was to " reimburse { her ] for the XXXX trip. '' The wire transfer to XXXX XXXX was to reimburse her for my portion of shared expenses we incurred on a scuba diving trip to XXXX. The shared expenses were incurred entirely as the result of transactions for activities in the United States and when we were in XXXX. 

The trip to XXXX was in full compliance with U.S. law, specifically 31 CFR Sections 695 et. seq. and with the instructions and interpretive guidance provided by the United States Department of the Treasury, Office of Foreign Assets Control. I signed and submitted the following documents before leaving the United States : OFAC Travel Affidavit Attached Print, complete, sign, and hold onto. 

This document serves as your affirmation of which general license category you fall under for legal travel to XXXX. 



XXXX XXXX XXXX XXXX XXXX and Itinerary Template Attached Each individual needs to print and sign their name on the certificate. For the date range, enter the dates you will be on the liveaboard ( Saturday-Saturday ) It is suggested to print this document and keep it accessible throughout your travels.

This supports your reason for travel that you declare on your Travel Affidavit and can be presented to US Customs if asked for validation. 



XXXX XXXX XXXX XXXX XXXX  in XXXX  Attached A version of the above certificate in XXXX  in case XXXX XXXX asks for the reason for your visit. Fill out the lines with your destination and the XXXX  you will be staying on. 





I checked my account on XX/XX/XXXX, and saw that the {$1600.00} was debited ( deducted ) from my interest bearing checking account. As of XX/XX/year> the funds were debited. The funds were not held in a " pending '' status. 

On Thursday, XX/XX/XXXX, XXXX XXXX called me to say that her bank, XXXX ( a U.S. financial institution ) had not received the funds. I called Citibank to initiate an inquiry. That evening, I received an email from Citibank informing me that I had received an encrypted email from Citibank. However, after following all the instructions and prompts on opening the encrypted message, I could not open the message and was constantly redirected into a circular series of " prompts. '' On Friday, XX/XX/XXXX, I reached a Citibank representative using the number on the back of my ATM card. I made the call at XXXX XXXX  and finally reached the representative at XXXX XXXX  after waiting " on hold '' for 4+ hours. I explained the problem that the {$1600.00} wire transfer had been debited from my account but had not reached the transferee 's account at XXXX. After a long wait, I was told that Citibank needed additional information. At that point, I asked the representative to cancel the wire transfer and that I would just write XXXX a personal check from the checking account. I did that. 

Beginning Monday, XX/XX/XXXX, I began checking my account on line. The {$1600.00} was not returned to my account. The wire transfer continued to be identified as " pending. '' I initiated a call to Citibank, and again after long waits, reached a representative who agreed to keep me on the line while she reached the wire transfer compliance department. I waited for a lengthy period. She returned to my call and informed me that compliance told her that my request for the wire transfer had incomplete information and that, because of the word " XXXX '' in the memo section, the funds were being held. I explained to her that the wire transfer was a domestic wire transfer to a U.S. financial institution, that the funds were not going to XXXX and that, in any event, I had asked that the wire transfer be cancelled and the funds returned to my account. I asked to speak to a supervisor. 

When I reached the supervisor, that individual told me that I would have to apply to the U.S. Department of the Treasury to receive a " license '' in order for the funds to be returned. I am an attorney ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ) and I asked for the controlling Code of Federal Regulations citation. He gave me a U.S. Treasury Department website link which was not operative. I went on the U.S. Treasury Department website, found the applicable controlling regulations and determined that prior to the trip, I had complied with all requirements pursuant to 31 CFR Sections 515 et seq. and with the applicable Treasury Department requirements and guidance for travel to XXXX. I called the appropriate section at the U.S.Treasury Department, and found a very helpful individual who told me, contrary to what the Citibank representatives told me, that the U.S. Treasury Department did not place a hold on my wire transfer request, that the U.S. Treasury Department regulations and sanctions involving XXXX did not require Citibank to refuse the transfer, to debit my account, and to refuse to return the funds and that I was not eligible to receive any kind of license before Citibank could return the {$1600.00} to my account. 

I again called Citibank, using a number that I obtained for the " wire compliance '' department. I again explained the situation in detail. The Citibank representative told me that she would forward all the information to the appropriate people. I asked her to return my call or have the appropriate person return my call for a status report. I never received a response. 

On Monday, XX/XX/XXXX, I again called Citibank to determine the status of this matter. Again, after a long period of time, I was told that Citibank had all the information necessary to cancel the wire transfer return the {$1600.00}. I had the telephone call on speaker, and thus I have a witness that the representative said that Citibank had all the information and did not need any information from me. 

Today, Tuesday, XX/XX/XXXX - two weeks after my initial request and 8 telephone calls and 14+ hours the wire transfer request is still listed in my account as " Processing ... .we are working on it ... '' The wire transfer is still listed as pending and the funds have not been returned to my account.