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Checking OFAC when Originating an ACH

Answered by: 
Kathleen Blanchard

Question: 
Do we need to check OFAC for payees when we originate an ACH?
Answer: 

This will totally depend upon the decisions reached via the bank's OFAC risk assessment. There is no specific requirement; you should look at transactions with similar risks, see how the bank handles OFAC for those transactions, make a decision and set a policy and procedure. You should make sure that international ACH transactions are considered (IATs), both incoming and outgoing.

First published on BankersOnline.com 5/03/10

First published on 05/03/2010

Filed under: 
Security
Filed under security as: 
ACH
OFAC

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