Text that we will expand later

BANK SECRECY ACT

  • Provides a secondary check on Political Exposed Persons (PEP)
  • Provides a secondary check for Money Service Businesses (MSBs) to prevent money laundering

USA PATRIOT ACT

  • Checks to ensure no entity is on the OFAC SDN list
  • Checks for MSBs

OCC BULLENTIN 2006-39 AND 2008-12

  • Monitors authorized returns and variances from established parameters (such as origination volume) for FIs who originate ACH
  • Identifies and monitors the third-parties who originate as a pass-through company for FIs who have third-party senders
  • Creates a projection of customer’s transactional behavior

FDIC FINANCIAL INSTITUION LETTER (FIL) - 41-2014

  • Monitors and profiles Third-Party Senders and the companies they originate for as part of Know your Customer’s Customer
  • Provides documentation to support adequate procedures for conducting due diligence, underwriting, and ongoing monitoring of third-party relationships

FDIC44-2008

  • Provides monitoring for downstream third-party relationships, providing compliance with the FDIC mandate for identifying and monitoring third-party risk

NACHA OPERATING RULES

  • Provides ODFIs with a commercially reasonable method to verify the identity of the Originator or Third-Party Sender (Article II Section 2.2.1)
  • Provides ODFIs with due diligence with respect to the Originator or Third-Party Sender in order to form a reasonable belief that they have the capacity to conform with NACHA Operating Rules (Article II Section 2.2.3)
  • Monitors ACH transaction and return data, allowing you to know the return rates for your originator by percentage (Article II Section 2.17.2)
  • Assists on compliance with Appendix 8 for audits, by helping you monitor your originators, transactions over time and return rates
  • Provides Third-Party Sender management by monitoring the third-party senders, with an option to monitor their originators. Know who you are originating for and Know Your Customer’s Customer (Article II Sections 2.2.1 and 2.2.3)

FINCEN SECTION 314(a)

  • Provides FIs and companies with the needed information to comply with law enforcement requests related to anti-money laundering activities

FFIEC 

  • Provides credit risk monitoring for RDC customers to address the FFIEC guidance “requirement” regarding credit risk monitoring for RDC customers