Quick pointers to ACH and IAT
Every depository financial institution (DFI) needs to understand the impact of the new rule on its ACH operations regarding OFAC compliance. DFIs can contract with other parties for ACH processing services but cannot contract away their liabilities and obligations related to OFAC compliance.
Also see, OFAC Compliance Implications
References
- There is a letter from the dept of treasury regarding the responsibilities at the bottom of this link
- FFIEC guideline before the IAT requirement
- OCC (old document again from 2006). See page 8 and 9
- NACHA guidelines
- NACHA Readiness checklist
- ABA Preparedness Checklist
- OFAC Letter to NACHA on purely domestic ACH (this is from 1997)
References for corporate
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Categories: Idola