I am trying to determine how to handle ACH transactions. With regard to OFAC, I've found the following article (
http://www.kirchman.com/comply/hot_issues/ACH-OFAC.html):
"The guidelines work on the assumption that everyone in the ACH processing chain does what NACHA's operating rules require them to do. Under OFAC rules, ACH originating and ACH receiving banks (referred to as ODFI's and RDFI's) are required to have sound Know Your Customer procedures in place which will prevent opening accounts for blocked parties subject to OFAC sanctions. Thus, you should never have a situation in which a blocked party as a customer of an ODFI originates ACH entries. Similarly, you should not have circumstances in which the RDFI will receive payments to the account of a blocked party since the RDFI should have either declined opening the account for that party or should have frozen the account on its books. The NACHA guidelines for processing domestic ACH transactions place great reliance on this chain of Know Your Customer determinations. Additionally, since 1997, NACHA rules have required Originator/ODFI agreements to include an acknowledgement by the Originator that ACH transactions it originates comply with the laws of the United States (including OFAC). All originating bank ACH contracts with customers should require the customers to screen for OFAC hits when originating ACH entries for the bank to process."
I am trying to determine, whether or not we need to be screening ACHs against the FinCEN 314(a) request list, OR, does the same logic apply?
Thanks!!