OFAC Policy & New International ACH Regs

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Question:

Do we need to do anything to our OFAC policy in regard to the new international ACH transaction regulations? We already run all names through OFAC.

Answer:

You should include in your OFAC policy the fact that you will be scanning incoming and outgoing, and if you will allow IAT origination through your bank or in your bank's name, IAT debit and credit and return entries, including their 7-12 addenda records, and describe the procedures you will follow if you identify any hits.

First published on BankersOnline.com 9/07/09