First things first, segregate the funds.
Your ACH batch can only be settled in part.
Is the name listed on a program that requires blocking, or one that permits rejection?
Second, ask the sending financial institution for whatever information you need to disqualify the match.
If no information is forthcoming, ask advice from OFAC.
Be prepared to treat it as a true match, with the required reporting to OFAC, and naming the sending institution.
Last edited by EdSpenser; 03/26/14 01:31 PM.