I viewed a previous post regarding this topic but still no clear answer.............. Please refer me to where it's stated that NACHA & OFAC agreed that the agreement between the Originator & ODFI must state Originator will comply with U.S. laws, including OFAC.

If the statement only states that the Company will abide with applicable laws and regulations, will that suffice? Or it's encouraged that OFAC be specifically stated?

Also, for those payroll entries initiated by the Company that are not "on-us" entries....must they be checked against the OFAC list? Does it matter if the entries are unbundled or not?

I am not very knowledgable about ACH, but this may help.