Notice to All Vendors Receiving Payment by EFT or ACH
Texas A&M University is obligated to comply with the requirements of the United States Department of Treasury Office of Foreign Assets Control (OFAC), which oversees payments sent outside the territorial jurisdiction of the United States. This includes automated clearing house (ACH) payments, such as electronic funds transfers (EFT). Effective September 18, 2009, the University is obligated to identify as an “International ACH Transaction” (IAT) any EFT payments that are (1) made by the University to a financial institution located outside the U.S. or (2) made by the University to a domestic financial institution if that financial institution immediately transfers the full deposit amount to a financial institution outside the U.S. in a “back-to-back” transaction.
If you have instructions with your recipient bank to immediately wire the full amount of the direct deposit to a foreign bank, we request that you complete a form that provides further details about the foreign transaction. The form, with instructions on completion and where to return, may be accessed here.
To comply with the OFAC requirements going forward, Texas A&M University will require that vendors confirm, at the time that they request that payment be made by EFT, that the EFT is being made to a domestic financial institution and will not be part of a “back to back” transaction to a foreign institution.