Which parties are subject to OFAC requirements in an ACH transaction?

In the context of an ACH transaction, all parties involved are subject to OFAC (Office of Foreign Assets Control) requirements. This includes the sender, the receiver, and any financial institutions facilitating the transaction. OFAC regulations are designed to enforce U.S. economic and trade sanctions against targeted foreign countries and regimes, terrorists, international narcotics traffickers, and other threats to national security, foreign policy, or economy.

When an ACH transaction is initiated, it is essential for every party along the transaction chain to ensure compliance with OFAC regulations. This means that the sender must not be listed on any OFAC-sanctioned lists, the receiver must also not be sanctioned, and the financial institutions handling the transaction must perform due diligence to ensure they are not facilitating a payment that violates these regulations. Therefore, the comprehensive nature of OFAC compliance in ACH transactions dictates that all parties have responsibilities to ensure adherence to these important regulatory requirements.