On September 18, 2009, an International ACH Transaction (IAT) rule from NACHA – The Electronics Payments Association, will go into effect This rule was created because of a request by the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) that the ACH requirements for international payments be changed. This new rule will make it easier for banks to comply with OFAC’s due diligence requirements. The new rule also requires all U.S. financial organizations that send and receive IATs to incorporate additional remittance data in order to identify the sender and recipients. Effectively, this rule madates that organizations include ancillary information to ensure that a payment is fully understood and available for further investigation.

If the IAT measures are not followed, financial institutions dealing in payments processed through the U.S. ACH Network can be penalized. These penalties range from $11,000 to $1,000,000 per violation. Given the severity of the penalties involved, all financial organizations should be moving quickly to make that the new rule is implemented and being enforced.