Had a question arise on a new product we are looking to introduce.
Not sure of the product name but it basically creates an ACH withdrawal, authorized by our member, but originated by the recipient. The question that I have is would we be required to perform an OFAC check on the person the money is going to be sent to?
I guess I already feel we should, I am just not sure how we would do this. On further thought it would just have to be a requirement of the product that there is some way to track these transactions. Looking for comments or suggestions.

Well, yes, you should check the payee against OFAC or other applicable sanctions lists. And yes, you should know how you are going to monitor the transactions before it goes into production.

You don't have to answer this, but what particular advantage do you have over, say, PayPal, in such transactions?