Which of the following parties are subject to OFAC requirements in an ACH transaction?

All parties involved in an ACH transaction are subject to OFAC (Office of Foreign Assets Control) requirements. This is because OFAC regulations are designed to prevent financial transactions that may involve individuals, entities, or countries subject to economic sanctions.

In an ACH transaction, there are typically several parties involved, including the sender (originator), the receiving party, and the financial institutions facilitating the transaction. Each of these parties has a responsibility to ensure compliance with OFAC regulations. This means they must screen for any entities or individuals on the OFAC lists and refrain from executing transactions that would violate these regulations.

For example, if the financial institution is processing the transaction, it must verify that neither the sender nor the receiver is on any OFAC lists. Additionally, the sender and receiver should be aware of their obligations under these regulations even if they are not processing the transaction directly. Hence, compliance is a shared responsibility across all parties involved in the transaction.