Answer:
Start by reviewing the Special Topic discussion on OFAC Compliance beginning on page OG 112 of the 2005 edition of NACHA's ACH Rules publication. As an ODFI you agree to the rules, and as an entity doing business in the U.S. you are subject to OFAC's rules, too.
The Special Topic discussion provides some common sense analysis to your question. For example, it suggests you use more care when originating an international transfer (if you handle these).
Obviously, you have to know whether your Originator is a blocked party. The NACHA guidelines suggest that you may be able to rely on the RDFI's responsibility to check the Receiver against OFAC's lists (except in the case of international transfers). But you should also be aware that, if the RDFI fails in its responsibility to check, the ODFI can be "on the hook" for allowing a transfer to be completed to a blocked party.
First published on BankersOnline.com 4/4/05
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