IAT Travel Rule

Can someone please confirm that this statement is correct. On 9/18/09 the Travel Rule will apply on all IATs in the amount of $3000 or more. So we will need to keep record of these transactions just like we do wires. Correct? Thank you!!

Yes:

On September 18, 2009, an amendment to the National Automated Clearinghouse Association (NACHA) Operating Rules will become effective that has the potential to impact U.S. businesses that send or receive ACH payments. This amendment will require all payments funded internationally or sent to another country via the ACH Network to be identified as International ACH Transactions using a new Standard Entry Class (SEC) Code—IAT. The new Rule will also require that IAT payments include specific data elements defined by the Bank Secrecy Act’s (BSA) “Travel Rule.”

Thanks!

There is no dollar limitation with IAT though is there? Isn't the information required on all IAT transactions?

No dollar trigger for the IAT travel rule info. All 7 required addenda records, where the info on the Receiver and Originator is carried, must accompany the entry.