Are ACH payments required to be screened for OFAC matches like funds transfers?

“Chance favors only the mind that is prepared”. Louis Pasteur

Current exam manual has a whole section on this. To summarize:

• If you Customer is an originator, you are responsible for checking them, not the recipient,
• If your customer is the recipient, you are responsible for checking them, not the originator.

Here is the catch. If your customer is a batch originator, the above rules apply, as long as you do not un-batch the ACH Batch to process on-us transactions. If you un-batch, you are responsible to checking originator and recipient.

See exam manual for full discussion and explanation of rule and exception.


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The above is my opinion only, for what it is worth.

See

http://www.membersunited.org/IAT/OFACcompliance_NACHAoperatingGlines.pdf

An addition to my answer above,for International ACH (IAT), you check everything.