05-EA-24: NACHA: OFAC Compliance and ACH Cross-Border Payments

Recently, NACHA, the Electronic Payments Association issued a request for comment with regard to ACH entries that involve offshore parties or correspondent accounts but that originate within the United States and therefore do not currently treated as cross-border transactions. These entries are of concern because they do not receive the same higher level of scrutiny as do cross-border entries using the CBR Standard Entry Class Code, as required by the Federal banking regulators and the U.S. Treasury Department's Office of Foreign Asset Control (OFAC).