Such policies might involve screening each unbatched ACH record. For the residual unbatched transactions in the file that are not "on-us," as well as those situations where banks deal with unbatched ACH records for reasons other than to strip out the on-us transactions, banks should determine the level of their OFAC risk and develop appropriate policies, procedures, and processes to address the associated risks. ODFIs acting in this capacity should already know their customers for the purposes of OFAC and other regulatory requirements. If an ODFI unbatches a file originally received from the Originator in order to process "on-us" transactions, that ODFI is responsible for the OFAC compliance for the on-us transactions because it is acting as both the ODFI and the RDFI for those transactions. If an ODFI receives domestic ACH transactions that its customer has already batched, the ODFI is not responsible for unbatching those transactions to ensure that no transactions violate OFAC's regulations. In this way, the ODFI and the RDFI are relying on each other for compliance with OFAC regulations. The Receiving Depository Financial Institution (RDFI) similarly is responsible for verifying that the Receiver is not a blocked party.
With respect to domestic ACH transactions, the Originating Depository Financial Institution (ODFI) is responsible for verifying that the Originator is not a blocked party and making a good faith effort to ascertain that the Originator is not transmitting blocked funds. "Because of the nature of ACH transactions and the reliance that ODFIs and RDFIs place on each other for OFAC reviews and other necessary due diligence information, it is essential that all parties have a strong CDD program for regular ACH customers.
OFAC APPLICATION STATUS CHECK MANUAL
217-224) on Automated Clearing Transactions – Overview, the manual states: It essentially appears to say that ODFIs are responsible for verifying the status of the originator and RDFIs are responsible for verifying the status of the receiver/beneficiaries. The Federal Financial Institutions Examination Council's (FFIEC) Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual has a section on OFAC compliance and ACH transactions that discusses the expectations for Originating Depository Financial Institutions (ODFIs) and Receiving Depository Financial Institutions (RDFIs). That basically means these accounts – and their related OFAC risks – should be addressed in your risk assessment, and then your policy designed to mitigate that risk. So, each credit union has to come up with an OFAC compliance program designed to ensure compliance based on the institution’s own risk. If a credit union facilitates a prohibited transaction, there is an OFAC violation. The conundrum here is that there isn’t a specific regulatory requirement that will tell you which transactions to run against OFAC. Lundegaard (the recipient)? And, should this be performed in real-time to allow for the transaction to be stopped? Should an Office of Foreign Assets Control (OFAC) check be run on both Mr.
![ofac application status check ofac application status check](https://mir-s3-cdn-cf.behance.net/projects/404/ccd80c129611527.Y3JvcCwxNTg2LDEyNDEsMCw1MDI.jpg)
Wade Gustafson is sending a domestic ACH to Jean Lundegaard through your credit union.