We recently had the OCC ask us if we were reviewing ACH originators and their transactions for AML/BSA issues. This is the first time I have heard of a regulatory agency "suggest" we start performing this type of review.

Anyone else had this request?
Thanks,

The ACH is clearly a substitute mechanism for wire transfers, particularly for domestic wires. It is a lot cheaper, and if you don't need same day effective dates, it's an effective way to move substantial chunks of value from one place to another.

ODFIs need to know their Originators fairly well in order to assess their ACH credit risk. That should include an understanding of the nature of the business and the purposes for which the ACH will be used. Will it principally be used for direct deposit of payroll? Will the business be using CCD entries to move funds among the business's accounts? Will corporate trade payments be made?

Leveraging that sort of information into an AML risk assessment doesn't sound like a giant leap.

The OCC gave you good advice and John has enhanced it considerably. Unmonitored, ACH is the sleeping giant of AML risk.