On September 18, 2009, a revision of the NACHA Operating Rules became effective. The revision contains a section known as the International ACH Transaction (IAT) rules, which are designed to align the NACHA Operating Rules with the requirements to the Office of Foreign Assets Control (OFAC). The IAT rules apply to domestic as well as international ACH transactions. All entities originating payments electronically, whether they be for payroll, pensions, or vendor payments, are therefore advised to examine the new rules to see how they apply. Origination of electronic payments includes submitting ACH credits to payees (for disbursements), as well as originating ACH debits to draft payers' accounts (for collecting funds).
Governmental entities will need to develop and document the procedures and processes they will implement to demonstrate the due diligence efforts they will undertake to comply with the new rules. To assist agencies in understanding and complying with the IAT rules, the State Controller has issued an "IAT Advisory." Agencies should refer to the IAT resources websites on a frequent basis as they will be updated whenever there are any new developments regarding the rules.
Links to IAT Resources
IAT Related Documents for Agencies
IAT Information for Employees and Vendors