Every party to an ACH payment is covered by OFAC rules, so a company that originates, receives or processes ACH has to screen the people and businesses on each file against the sanctions lists, hold anything that looks like a match, and keep a dated record of the decision. Banks screen on their side, but the bank does not replace your own check. If you run payroll, collect rent, pay vendors by ACH or sell a payments product, the practical question is how to screen incoming and outgoing ACH counterparties without slowing every batch. For most small and mid-size ACH users that costs between $24 and $250 a month, far less than a full payments compliance platform.
Do you have to screen ACH payments for OFAC
Yes, in the sense that OFAC liability is strict and applies to every U.S. person, not only to banks. A payment to or from a blocked party is a violation whether or not you knew. The Nacha rules add a specific duty for international ACH transactions (IAT), where the receiving bank has to screen the incoming item. Domestic ACH is less prescriptive, but banks and sponsor banks pass their obligations down to their originators and processors through the agreement you signed. Many of those agreements ask for proof of a sanctions program. Check the exact wording with your bank and with current Nacha Operating Rules, because this page is a buying guide, not legal advice.
Who needs ACH screening software
- Payroll and PEO companies that add new employees and contractors every pay run.
- Property managers and landlords collecting rent from many payers.
- Lenders and servicers that collect loan payments and fund by ACH.
- Accounts payable teams that pay vendors, especially new foreign or unfamiliar ones.
- Fintech and payment facilitators that originate ACH for their own customers.
What to screen in an ACH flow
Screen names, not account numbers. The sanctions lists contain names, aliases, addresses and identifiers, so a check needs the account holder name and, for businesses, the legal name and owners. Typical points are onboarding of the payer or payee, every new beneficiary added to a payment run, a periodic rescreen of the saved file after each list update, and any item your bank returns with a sanctions question. If you originate for third parties, you also need to screen those clients at onboarding.
| ACH situation | What to check | When |
|---|---|---|
| New payroll hire or contractor | Full legal name, country | Before the first payment |
| New vendor on an AP run | Business name, owners where known | Before the first payment, then after list updates |
| Rent or loan payer | Payer name | At onboarding, then monthly or on update |
| Cross-border item (IAT) | Originator, beneficiary, intermediaries | Before release, expect the bank to screen too |
| Third-party originator client | Business and its principals | At onboarding and ongoing |
Options for screening ACH counterparties
| Option | Entry price | Fits | Record per check |
|---|---|---|---|
| OfacScanner Starter | $49 a month, or $24 a month billed yearly | Checking new payees one at a time, 1,000 checks a month | PDF with list version, time and user |
| OfacScanner Growth | $499 a month, or $249 a month billed yearly | Uploading a payee or payer file as CSV and rescreening it after list updates | PDF plus a case with the reviewer's decision |
| OfacScanner Scale | $1,999 a month, or $999 a month billed yearly | API and webhooks to screen inside your payment flow before release | PDF per check through the API |
| Bank or network service | Ask your bank | Screening done by the institution on its side of the item | Held by the bank, not by you |
| Full payments compliance platform | Quote only | Transaction monitoring, fraud and sanctions in one system | Case records in the platform |
| Treasury Sanctions List Search | No charge | One name at a time | None, you capture a screenshot |
Prices for our plans are on the pricing page. Check other vendors' pages yourself before you compare, since quotes and tiers change.
How to handle a hit before an ACH batch releases
Hold only the affected item, not the whole file. Compare the name, address, date of birth and country on the listed entry with what you collected. A common name with a different birth year is a false positive: release the item and write down why. If you cannot rule the entry out, keep the payment on hold, confirm it against the official Treasury search and bring in your compliance officer or counsel. Blocked property is reported to OFAC within 10 business days. The reason to screen before release is simple: it is far easier to stop an ACH item before settlement than to unwind it afterward.
What the record should show
An examiner or sponsor bank usually asks four things: who was screened, against which lists, when, and what you decided. A record that shows the list version and the time answers the first three. A note from the reviewer answers the fourth. OFAC recordkeeping runs 10 years, see our guide to OFAC recordkeeping requirements. For batches, pair the screening with batch sanctions screening, and for payment flows inside an app see payment sanctions screening.
Which plan fits an ACH user
A small payroll shop or landlord that adds a handful of payees a week is well served by Starter and a saved PDF per payee. A company with a file of thousands of employees, tenants or vendors should be on Growth, so the whole file is screened in one upload and rechecked automatically when OFAC changes the lists. A payments company that originates ACH for clients and wants a check inside its own flow needs Scale. Accounts payable teams that want the invoice side automated can look at accounts payable automation software, and screening new vendors before the first payment is the step that keeps the run clean.
Type a real payee name into the OFAC search console at the top of this page and open the PDF it produces. If that record would satisfy your bank, you have your answer. Results are a lead, not a legal decision, so confirm likely matches against the official Treasury list before you block, reject or report a payment.