IAT Compliance Deadline is Tomorrow (September 18, 2009)

Are you ready for the deadline???

The delay of the original compliance date for NACHA’s IAT rule is nearing an end as the revised compliance date, September 18, 2009, is around the corner. Actually, it is tomorrow! The rule requires that an international ACH transaction entry contain a list of required information as well as BSA’s "Travel Rule" data.

An International ACH Transaction is defined as an ACH entry that is part of a payment transaction involving a financial agency’s office that is not located in the territorial jurisdiction of the United States. Financial agency means an entity that is authorized by applicable law to accept deposits or is in the business of issuing money orders or transferring funds.

An office of a financial agency is involved in the payment transaction if it:

1. holds an account that is credited or debited as part of a payment transaction; or

2. receives funds directly from a Person or makes payment directly to a Person as part of a payment

transaction; or

3. serves as an intermediary in the settlement of any part of a payment transaction.

Fortunately, NACHA does provide a wealth of information on its website on the rule, including FAQs, which you can access by clicking IAT Rule Helpful Materials.

If you still need help or have questions in this area, particularly related to the AML and OFAC compliance issues that affect processing of IATs, please contact shassett@lubrinco.com