NACHA rules require every ACH payment entering or exiting the United States to be identified and formatted as an International ACH Transaction (IAT) and EACH transaction must be reviewed for OFAC compliance. All U.S. financial institutions are affected by this rule, even those that do not currently send or receive international ACH payments as any financial institution may potentially receive an IAT transaction. Every financial institution needs to understand how it is impacted by the new NACHA rule. Penalties for non-compliance with OFAC's regulations can be severe.
This publication includes all IAT changes to the NACHA Operating Rules since 2009, mapping for Identification of Additional Parties in For-Further-Credit/Debit-To Model, OFAC compliance and responsibilities of financial institutions and Gateways.