In unbatched ACH transactions, which party is responsible for OFAC compliance?

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Multiple Choice

In unbatched ACH transactions, which party is responsible for OFAC compliance?

In ACH, the institution that originates the entry bears the responsibility for OFAC screening. For an unbatched item, the originating depository financial institution (the bank that submits the payment into the ACH network on behalf of the originator) must perform OFAC screening before sending the entry. If a match to the sanctions list is found, the item is blocked or returned. The receiving bank (the RDFI) handles items it receives but does not origin the payment, so the primary OFAC compliance obligation sits with the ODFI.

In ACH, the institution that originates the entry bears the responsibility for OFAC screening. For an unbatched item, the originating depository financial institution (the bank that submits the payment into the ACH network on behalf of the originator) must perform OFAC screening before sending the entry. If a match to the sanctions list is found, the item is blocked or returned. The receiving bank (the RDFI) handles items it receives but does not origin the payment, so the primary OFAC compliance obligation sits with the ODFI.

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