Know Your Customers and their Customers

At the end of the day, do you really know your customers?

A Nested Third-Party Sender looks like a typical originating customer but is actually a customer that originates ACH transactions for its own customers. This type of customer creates an additional level of risk for an ODFI because the originating institution may not actually realize what types of businesses it is working with. To protect itself from this type of risk, the ODFI not only needs to know their customers (KYC) and their customer’s customer (KYCC), but also their customer’s customer’s customer (KYCCC).