How are the payments hitting the account? ACH, debit card? Also, I don't know what TCH is.
For domestic ACH payments I can tell you that each institution can rely on each other to screen their own customers. From the exam manual:
"With respect to domestic ACH transactions, the ODFI is responsible for verifying that the Originator is not a blocked party and making a good faith effort to ascertain that the Originator is not transmitting blocked funds. The RDFI similarly is responsible for verifying that the Receiver is not a blocked party. In this way, the ODFI and the RDFI are relying on each other for compliance with OFAC regulations."
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