How does the ODFI know the funds will ultimately move international?
It is the responsibility of the ODFI to educate their Originators and the responsibility of the Originators to review their client files to determine if IAT might be needed. One clue to watch for would be foreign addresses in Receivers customer files. In that example, the Originator should contact the Receiver. Some Originators will choose to be cautious and use IAT when they suspect the funds will move internationally. ODFIs must do their due diligence with their customers to communicate and educate on IAT. ODFIs must have proper agreements with their Originators that address this. 23. For Companies/ACH Originators that offer payroll cards to employees that do not have a U.S. bank account and primarily use the card outside the U.S. territory and the payroll card is funded via an ACH file, will the payroll card funding need to be originated as an IAT? It will depend on where the account is held that serves for the payroll card. If the funding only moves within the US, even though the c
