That's not a requlatory requirement nor was it suggested by the federal functional regulatory agencies or FinCEN. It is purely a NACHA suggestion and would be subject to comment only in an ACH related review.
From me, not them, your OFAC risk assessment should include an evaluation of IAT related activity. It is not mentioned in the current appendix M.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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