Our business customers have the capability to use thier own computer to originate an ACH transaction. For those of you who also do this, do you require a dual control environment; that is two employees at the customer business(a preparer and approver) to originate an ACH batch?

We leave the customer internal controls up to the customer. Our agreements contain language to indicate that the customer is solely responsible for implementing appropriate controls. The reason for this is because each customer relationship varies in complexity. It's a lot easier to implement dual control in a 10-person accounting firm than in a 2 person maintenance shop, for example.