In International ACH Transactions, which party must comply with OFAC regardless of the OFAC flag?

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Multiple Choice

In International ACH Transactions, which party must comply with OFAC regardless of the OFAC flag?

In OFAC compliance for International ACH Transactions, the Receiving Depository Financial Institution has the primary obligation to apply OFAC rules to inbound items, even if the OFAC flag on the file isn’t set. The RDFI is the party that actually credits or debits the recipient’s account, so it must verify that the incoming entry does not involve a sanctioned individual or entity and take action (such as returning or blocking the item) as needed. The Originating Depository Financial Institution screens outbound items, but the responsibility to prevent credit to sanctioned parties rests with the RDFI when funds arrive. That’s why the RDFI must comply with OFAC regardless of the flag.

In OFAC compliance for International ACH Transactions, the Receiving Depository Financial Institution has the primary obligation to apply OFAC rules to inbound items, even if the OFAC flag on the file isn’t set. The RDFI is the party that actually credits or debits the recipient’s account, so it must verify that the incoming entry does not involve a sanctioned individual or entity and take action (such as returning or blocking the item) as needed. The Originating Depository Financial Institution screens outbound items, but the responsibility to prevent credit to sanctioned parties rests with the RDFI when funds arrive. That’s why the RDFI must comply with OFAC regardless of the flag.

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