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If a US Company originates payments that are international but uses the banks proprietary system, instead of the US ACH Network, are these payments IAT?

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If a US Company originates payments that are international but uses the banks proprietary system, instead of the US ACH Network, are these payments IAT?

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If the entries are not sent through the US ACH Network, the entries do not need to be coded as IAT. The Originator is still subject to OFAC requirements and the bank should screen the information for OFAC compliance. 16.

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