Processing Cross Border Payments as of September 18, 2009

Effective September 18, 2009, an amendment to the NACHA Operating Rules (Rules) will require:

1. Originating Banks to identify all international payment transactions transmitted via the ACH Network as International ACH Transactions using a new Standard Entry Class Code (IAT); and
2. IAT transactions to include the specific data elements defined within the Bank Secrecy Act’s (BSA) “Travel Rule” so that all parties to the transaction have the information necessary to comply with U.S. law, which includes the programs administered by the Office of Foreign Assets Control (OFAC).

This amendment will align the Rules with OFAC compliance obligations and make it easier for Receiving Banks to comply with those requirements.

All clients must provide additional information with each payment record sent to the USA. Please refer to your Input File Formats to obtain details on these new records. If you have questions, contact the Cash Management Client Service Support.