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