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International ACH transactions (IAT) require special handling. Every IAT item that is presented in ACH files will show in GOLD ExceptionManager (GEM). Due to the IAT handling requirements, these can only be returned through GEM so all IAT records are retained in GEM in case a return is needed.
When ACH files are received by FPS GOLD for processing, a program (OfacChecklat) searches for IAT batch items included within the ACH files. When the batch is an international ACH batch, each transaction within the batch is validated against the OFAC sanctioned files. The following fields are checked:
•Originator Name
•Receiving Company or Individual Name
•Originating Financial Company Name
•Foreign Correspondent Bank Name
If any of these names match any of the OFAC sanctioned file names, the transaction is not validated. The originator country is also compared with sanctioned countries; if it is sanctioned, the transaction is not validated.
When an IAT item does not flag an OFAC match, the system will then send the IAT item through an additional validation for any other exception conditions that may exist on the account (such as NSF, Hold Code, or Stop Payment). If there are no other conditions, the IAT item will be posted to the account. It will show in GEM as Host Posted (HP) and displays “IAT-OFAC” in the Comments. If any other exception condition(s) exist, the item will be handled according to your organization’s GEM posting preferences and may reject due to another condition. In this case, the item will still display “IAT-OFAC” in the Comments. Other conditions will also be listed on your GEM report (FPSDR096) and in GEM on the item’s Exception Messages tab (Excep Msgs).
Example of an IAT Validated Item Host Posted
Example of an IAT Validated Item with Other Exception Condition(s)
When an IAT item flags a possible OFAC match, the item is sent directly to GEM and displays “IAT” in the Comments. These items are not checked for other possible reject conditions. It is the responsibility of your organization to carefully review the OFAC match to determine whether the item should be returned or posted to the account. If it is decided that it should be posted, the account should then be carefully reviewed for any other conditions that might exist on the account that would be reasons to return the item (such as NSF, Hold Code, or Stop Payment).
Example of an IAT Non-Validated Item