Account Disclosures. RDFI should review and update account disclosures to address:

Similar documents
International ACH Transaction (IAT) Exception Handling. Presented by Laura Nelson, AAP, NCP Auditor/Education Specialist

Copyright 2017 Lakeland Bank. All rights reserved. This material is proprietary to and published by Lakeland Bank for the sole benefit of its

Session 8: ACH. New York Bankers Association-Community Bank Auditors Group Internal Audit Training-June 6-8, 2016

OBLIGATIONS OF ORIGINATORS

Same Day ACH: Moving Payments Faster

Old Point ACH Services Annual Training 2014

Returns File Format. Revised 6/10/2010 Page 1 of 8

IAT Modifications Request for Comment. Executive Summary and Rules Description August 15, 2012

Key Components of an RDFI. Mini Deck

5/2/2017. Mini Deck. Disclosure

Get on First Base with Same-Day ACH Risks

ORIGINATING ACH ENTRIES REFERENCE

ACH Management Policy

ARE YOU READY FOR SAME DAY ACH??

Presented by: Jen Wasmund, AAP, NCP Vice President of Education and Compliance. Jordan Morell, AAP, NCP Associate Director of Education Services

NACHA Rulemaking Process Update

OFAC Compliance Officer Responsibilities. OFAC Regulations. Transactions Subject to OFAC. Reviewed by and Date:

ACH FUNDAMENTALS: UNDER THE MICROSCOPE. Heather Spencer, AAP Implementation Coordinator, MY CU Services, LLC. Disclaimer

CORPORATE USER ACH QUICK REFERENCE CARD

ACH Industry Update, Audit Weaknesses and Emerging Payment Trends

New ACH Stop Payment and Written Statement of Unauthorized Debit Requirements

Same Day ACH and PEP+ Opportunities. August 21, 2015

Agenda. New ACH Stop Payment and Written Statement of Unauthorized Debit Requirements. ACH Stop Payment Requirements Regulation E

Directory of ACH Return Codes

Payment System Rules and Regulations. What will you learn? After this course, you will be able to:

Same Day ACH: It s Here, You Need to Prepare

Treasury Management Services Product Terms and Conditions Booklet

IAT Modifications Proposed Modifications to the Rules August 15, 2012 ISSUE #1 - IDENTIFICATION OF COUNTRY NAMES WITHIN IAT ENTRIES

ACH Credit a transaction through the ACH network originated to pay a receiver (deposit funds into an account).

Performed by: The Payments Authority, under the oversight of AuditLink. October 22, 2013

Virginia Department of Taxation

RISKS WITH SAME DAY ACH

Same Day ACH: What Does It Mean to Your Financial Institution?

A2A EXTERNAL FUNDS TRANSFER SERVICE ADDENDUM TO ONLINE BANKING SERVICES AGREEMENT

ACH Originator Resources

Expanding Same Day ACH

Risks with Same-Day ACH. Presented by Kevin Olsen, AAP NCP Senior Vice President, Payments Education

UMACHA 2014; All rights reserved 2

2016 Annual ACH Audit CU*Answers

This is designed to provide those who are not familiar with the ACH Network with a basic understanding of the fundamentals of the ACH Network.

Authorizations & Agreements. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor

NOTICE OF AMENDMENT TO THE 2016 NACHA OPERATING RULES SUPPLEMENT #1-2016

The Green Book & ACH Payments

P2P, A2A Payments: Perils to Protection. WACHA Conference 2016 Kimberly W. Rector, AAP

Introduction. Page 1. Introduction

2015 NACHA COMPLIANCE SUMMARY GUIDE

FedGlobal ACH Payments Service Origination Manual

NACHA Operating Rules: What Do They Mean to You?

Same-Day ACH A New Rule; A New World. August 21, 2015 Puerto Rico Same Day ACH Symposium

UNFCU Digital Banking Agreement

INTERNATIONAL ACH TRANSACTIONS. IAT Scenarios Simplified

Virginia Department of Taxation

UCC (Uniform Commercial Code) Article 4A. Mini Deck

UCC (Uniform Commercial Code) Article 4A

AUTOMATED CLEARING HOUSE (ACH) THIRD PARTY SERVICE PROVIDER ADDENDUM TO THE BUSINESS ONLINE USER AND ACCESS AGREEMENT

Glossary of ACH Terms

Automated Clearing House

Key Information in Electronic Report Delivery (ERD) Reports - NOC

March 1, NACHA OPERATING RULES AND GUIDELINES ERRATA #1

Navigating the ACH Rules

Commercial Banking Online Service Agreement

Definitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions?

New Rules & Faster Payments

Treasury Management Services Product Terms and Conditions Booklet

ACH Tax Refunds: Exceptions, Posting, & Liabilities. Presented by Laura Nelson, AAP, NCP Auditor/Education Specialist

TREASURY MANAGEMENT MASTER AGREEMENT TERMS AND CONDITIONS

CASH MANAGEMENT SCHEDULE. AUTOMATED CLEARING HOUSE SERVICES for Originators & Third-Party Senders

NEACH Payments Management Conference ACH Credit Risk: Credits, Debits, Same Day

REGULATION GG YOUR NEW OBLIGATIONS TO STOP UNLAWFUL INTERNET GAMBLING

Funds Transfer Services

Paying the Employee Section 5

BETHPAGE FEDERAL CREDIT UNION INTERNET BILL PAYMENT CONSUMER AND BUSINESS MEMBER AGREEMENT

Presented by: Dennis Ansbro and Zoya Faynleyb ACAMS Greater Philadelphia Chapter December 10,2015

MEMORANDUM. December 7, CU*Answers Executive Council CU*Answers Board of Directors. From: Patrick Sickels Internal Auditor CU*Answers

CARPENTERS COMBINED FUNDS ELECTRONIC FUNDS TRANSFER (EFT) AUTHORIZATION FORM Please print or type all required information.

Applied Risk Management

NACHA Setup and Troubleshooting (Updated 09/04/2018) Steps for setting up your NACHA file:

Is it an Unauthorized ACH Debit or Consumer Fraud? Biller Best Practices

Automated Clearing House (ACH) Rules for Originators Trinidad and Tobago

INTRODUCTION TO SAME-DAY ACH

ACH Audit and Risk Assessment: Choose Your Own Adventure

Business to Business Payments

(For sweep accounts.) Total dividends earned as of the last day of the statement period. (For line of credit.) Amount advanced today.

UNDERSTANDING ACH First Tennessee Bank National Association. Member FDIC.

Managing Third Party Risk in the ACH Network

ACH Origination Agreement (Company) has requested that Easthampton Savings Bank (bankesb) permit it to initiate Entries to Accounts maintained at the

Service Agreement. UltraBranch Business Edition. alaskausa.org AKUSA R 05/15

ONLINE BANKING DISCLOSURE STATEMENT AND AGREEMENT

Pain Points in the Rules Phase Two Request for Comment and Request for Information. Executive Summary and Rules Description June 27, 2011

December 3, ACH Rulebook Subscribers. Cari Conahan, AAP Senior Director, Network Rules

Country Bank Cash Management Agreement

Payment Processing 101

Treasury Management Services Product Terms and Conditions Booklet

Same Day ACH: Preparing for Debits. Presented by Laura Nelson, AAP NCP Education Specialist/Auditor

Same Day ACH Progress Report Looking Ahead. Ryan Waterman, AAP, AVP, Risk & Regulatory Compliance

HIPAA Summit ACA Operating Rules Update. NACHA The Electronic Payments Association

February 6, 2015 BY COURIER AND ELECTRONIC DELIVERY

External Account Transfer Agreement July 16, 2014

Liberty Bankers Life Insurance Company

NAVY FEDERAL BUSINESS SERVICES DISCLOSURE BOOKLET. navyfederal.org Federally insured by NCUA Navy Federal NFCU 97BD (3-16)

Transcription:

IAT for the RDFI

RDFI Obligations Account Disclosures OFAC Screening (Accounts) Acceptance and Screening of IAT Transactions Policies and Procedures (including OFAC) IAT Credit Processing Sample Procedures IAT Debit Processing Sample Procedures Processing Exception and Disputed Entries Account Statement Requirements Corporate Receiver Request for Information Charging Fees for Processing 2

Account Disclosures RDFI should review and update account disclosures to address: Potential delay in posting IAT transactions Freezing or Blocking accounts/transactions Consumer and Commercial customers are affected 3

RDFI Procedures OFAC Screening The FI is required to screen its customer database against the most current OFAC SDN list The frequency of the screening must be guided by the FI s internal policy and procedures 4

RDFI Procedures General OFAC Screening The FI must screen new accounts prior to opening FIs should compare all new accounts with OFAC s SDN list prior to account opening or shortly thereafter If FI performs OFAC screening after account opening, procedures need to be in place to prevent transactions (other than initial deposit) from occurring until the screening is completed If someone wants to open a new account and their name is on the SDN list Verify that this is the same person as on the SDN list If yes, the FI cannot open the account If no, proceed with account opening 5

Use of a Third Party The RDFI may utilize the services of a thirdparty to perform OFAC screens The RDFI is ultimately responsible for the compliance, no matter who does the screening RDFI cannot contract away this liability RDFI staff should understand what fields the third party is screening 6

What type of Account is Required for Blocked Funds? The RDFI must make sure blocked funds are placed into an interest bearing account Only OFAC authorized debits may be made out of this account OFAC must be notified within 10 business days about the blocked funds 7

If There is a SDN Match All accounts for the matched name should immediately be frozen so no funds can be withdrawn The appropriate FI officer should be notified immediately The name of the customer, transaction and account details will be needed to file the appropriate report with OFAC Report can be found on OFAC s website http://www.treas.gov/offices/enforcement/ofac/ 8

Domestic ACH Transactions OFAC Screening The RDFI is required to reject or freeze transactions destined for a blocked account The ODFI & RDFI may rely on each other for OFAC compliance regarding their respective customer ODFI rely on RDFI for OFAC compliance regarding the Receiver RDFI rely on ODFI for OFAC compliance regarding the Originator 9

Acceptance and Screening of IAT Entries RDFI must accept all IAT entries All IAT Entries MUST be screened and cleared against the SDN list prior to posting Review even if the OFAC Screening Indicator reflects the Entry has already been screened Check all parties associated with the IAT Entry Includes memo posting Entries can be returned for appropriate reasons ( clean transactions or at the advice of OFAC) 10

What Fields are to be Screened on IAT Transactions? For inbound IATs the RDFI is responsible to review ALL parties to that transaction Receiver s Name Originator s name and physical address of Originator Originating Financial Institution Name, Identification, branch country code Receiving Financial Institution Name, Identification, branch country code Receiver s identification and physical address Remittance Information in the Payment Related Information contained in the optional Remittance Information addenda records The RDFI is responsible to review this information even if the OFAC Screening Indicator Fields are populated with a 0 11

Demonstrating Compliance The FI should develop a written ACH OFAC Compliance Policy that is clear and thorough Can be part of the FIs overall OFAC Policy Ensure staff is properly trained on the handling of Inbound entries, returning entries and NOCs 12

IAT Credit Processing Sample Procedures Review all incoming transactions for OFAC compliance Review even if the OFAC Screening Indicator reflects the Entry has already been screened Post clean transactions according to normal posting process Investigate suspect transactions Suspect transaction cleared by investigation Normal posting process Suspect transaction confirmed as an OFAC hit Post transaction Freeze account, if not already frozen Contact OFAC about next steps 13

IAT Debit Processing Sample Procedures Review all incoming IAT debits for OFAC compliance Review even if the OFAC Screening Indicator reflects the Entry has already been screened Post clean transactions according to normal posting process Investigate suspect transactions Suspect transaction cleared by investigation Normal posting process Suspect transaction confirmed as an OFAC hit Contact OFAC directly for further instructions If OFAC gives permission to return, use R16 (Account Frozen) Includes transactions intended for an account with a debit block/filter 14

Processing Exceptions Returning Entries Inbound IATs will be returned using the domestic return reason codes and return time frames as outlined in the ACH rules Outbound IATs will be returned to the U.S. ODFI using the timeframes of the receiving country (i.e., ODFIs may receive returns outside the normal return timeframe) 15

Returning Disputed IATs RDFIs can return a disputed Entry(s) if: The Entry(s) should be screened prior to returning If the screen comes back clean, proceed as usual If the screen comes back with hit, do not return, instead contact OFAC Return reason code R16 (Account Frozen/Entry Returned Per OFAC s Instructions) should be used if OFAC requests the FI to return the entry 16

Accounts with Debit Blocks If the FI receives an IAT debit for an account that has a debit block on it and the debit is not an OFAC hit Return the IAT debit R16 (Account Frozen) or R29 (Corporate Customer Advises Not Authorized) If the IAT debit is an OFAC hit Contact OFAC directly for further instructions 17

Processing NOCs Sending NOCs on IATs are allowed but many countries do not recognize them Seven mandatory Addenda Records ( Travel Rule ) are not required to be returned with the NOC IATCOR must be in Field 3 (IAT Indicator) of the Company Batch Header Record Refused NOCs are not supported 18

Stop Payments Stop payments may be placed on IAT entries Entry should be returned using the Return Reason code R08 (Payment Stopped) Entry must be returned within 2 banking days 19

Account Statement Requirements The RDFI must provide on the customer s statement, in addition to the required minimum information The secondary SEC, if available, which would be located in the first addenda record of the IAT transaction 20

Corporate Receiver Request for Information If the RDFI receives a request from its corporate customer for the remittance information, the RDFI is required to provide this information within 2 business days This information is found in the Remittance Addenda Record of the IAT transaction 21

Charging Fees for Processing The RDFI may charge fees for processing IATs due to the additional processing requirements associated with IATs NACHA ACH Operating Rules do not address fees charged by financial institutions 22

Contacting OFAC OFAC s Hotline Number 1 800 540 6233 www.ofac.gov 23