I noticed this morning that we are receiving IAT’s where the originator is using their eBay username instead of their real name. Example: 2012yanyan2012 This is obviously not the persons real name so it does me no good to OFAC Check this name.

I was wondering if anyone else has seen this and if so how are you handling these transactions?

Any information you can give me will be greatly appreciated.

I haven't seen this on our report.

I get IATs like this also and I use what info we have to do the OFAC check. I assume that is the name of their eBay "store" or Internet business.

I just OFAC whatever I can identify as a name, whether business name, handle, etc. I figure better safe than sorry!

We are also seeing IAT's where the originator appears to be a PayPal username. Our ACH department has reached out to UMACHA for further guidance and they responded that they reached out and PayPal is investigating. They also mentioned that they have had no other complaints from other banks about this. We didn't receive any clear answers or guidance from UMACHA.

Not true.

Even if it was true (see EdSpenser Post) that does not diminish your request.

One thing we learned on this topic from PayPal (at least so far) is that PayPal has a kind of 'basic account' for which they do either no CDD or some abbreviated version.

After talking to EastPay and the Orginating Bank we have made the determination to start returning any IAT that comes in with an Ebay username. I have been told that the Orginating Bank has contacted PayPal and are working on a solution. So...until something changes we are not taking any chances.

Would be nice if all entries were originated correctly. That being said, as the receiver of the entries, you are not required to match the name with the account name. Isn't the OFAC scan the responsibility of the ODFI ?

it would be if this were an intra-US ACH. However, IAT are cross-border and the ODFI may not be subject to OFAC regulations.

What are you planning to use as your return reason code?

We are using Return Code R17.

When did all of you start noticing this "problem"?

I came across it last week when the person who usually checks IATs was out of town. I looked back at our spreadsheets and noticed an increase in them around April of this year.

I started noticing it within the last year.

Are any of you seeing PayPal IAT credits at all? I monitored IATs daily for nearly 4 years, and I don't think I ever saw an IAT credit from PayPal. We had a customer at my old bank that would occasionally have large PayPal IAT debits. At the time, we called customers whenever they had IATs to make sure everything was okay. This customer always told me that the large debits were refunds to customers. However, I never once saw a PayPal IAT credit go into their account from that person. Nor could I ever identify a comparable PayPal credit into their account. There may be a reasonable explanation, but my opinion has always been that PayPal (possibly because they bundle credits, possibly not) doesn't properly identify IAT credits with regard to info that's accessible by us.

Why the quotes around 'problem'?

Irony. BeckyF may be a hipster. Don't judge.

Ah, then I'll just sit back and sip a locally sourced, artisanal iced team with muddled mint.

PayPal Consent Order

Interesting that this was done by a State. We should see the use of user names disappear I would imagine.

If I was a bank, I would just be rejecting them anyway.

I think that's defensible on the grounds that the true originator or beneficiary cannot be identified.

I'm in the process of researching NACHA guidance on data quality in IATs? Has anyone else gotten information from NACHA on the presence of false or 'manifestly meaningless' names as originators or beneficiaries in IATs?

Updated question to this post - PayPal has done absolutely nothing to change the name on the transactions they are sending. The user name is still sent as part of the transaction and we banks get potential matches all the time on a "username", not the true name of the sender / receiver. To top that, the last post before mine here was from 2013 -and PayPal was fined $7.7 million last year for OFAC violations.

AND - Wells Fargo, their bank, pays someone to sit there and take bank calls, forward the information to PayPal, get the user name and then sends it back to the inquiring banks so that they can vet their potential OFAC hits.

This is ridiculous - we cannot rely on PayPal to take care of it so we have to do it.

QUESTION --- what does your bank do with potential PayPal Username OFAC matches ?? Do you only follow through on a certain $ threshold, do you inquire on all, etc?

Thanks.