A Third Party Sender is defined as an intermediary between the ODFI and the originator that performs ACH origination services on behalf of an originator or another Third Party Sender.
Financial institutions that have this Third-Party Sender relationship should be aware of not only the new network Rule, but also the regulatory guidance and implications this type of relationship can have on the ODFIs BSA/AML program.
Objectives of the Presentation
Why should you Attend
- Define a Third-Party Sender and the minimum information about them to register with NACHA
- Illustrate how to identify a Third-Party Sender relationship and tips on how to keep up on this going forward
- Outline maximum timeframe to complete the registration process to be in compliance with the NEW Rule
- Identify how regulatory requirements with BSA/AML for the ODFI affects relationships with Third-Party Payment Processors (Third-Party Senders)
- List best practices used in the industry when entering or continuing in a Third-Party Sender relationship
- Describe the risk factors and risk mitigation with BSA/AML and Third-Party relationships and what that means
With the implementation of this new Third-Party Sender Rule, effective in September 2017; ODFI's need to be able to identify if they have a Third-Party Sender relationship and report accordingly (a. they do or (b. they don't with NACHA.
This session will outline how to identify a Third-Party relationship and what minimum information is required for the registration process, and outline the details of how to ensure you are continually in compliance with this new rule, not only in September but also into the future.
A Third-Party Sender is also a type of Third-Party Payment Processor and the FFIEC indicates that processors generally are not subject to BSA/AML regulatory requirements. As a result, some processors may be vulnerable to money laundering, identity theft, fraud schemes, or other illicit transactions, including those prohibited by OFAC.
The bank's BSA/AML risks when dealing with a processor account are similar to risks from other activities in which the bank's customer conducts transactions through the bank on behalf of the customer's clients. When the bank is unable to identify and understand the nature and source of the transactions processed through an account, the risks to the bank and the likelihood of suspicious activity can increase.
This session will help identify what the requirements are with BSA / AML in relation to this new Third-Party Sender Rule.
Who will Benefit
- Highlights of how to determine a Third-Party Sender relationship and methods used to help identifying
- How regulatory requirements affect this type of relationship for the ODFI
- ACH Network Rule on Third-Party Sender Registration that becomes effective September 2017
- Tips on preparing for the TPS Rule based on your role at the ODFI (internal audit, compliance, risk management, cash management)
- BSA/AML requirements of third party relationships and regulatory expectations based on industry threats
- Preparing for regulators examining your BSA/AML processes to ensure you've included any third-party sender relationships
- Best business practices for approving, onboarding and maintaining third-party sender relationships, and ensuring you are in compliance with the NEW Third-Party Sender Rule in September and in the future
- ACH Operations Staff
- Compliance Officers
- ACH Auditors
- ACH Managers
- Electronic Payments Professionals
- AAP's – keeping up with changes in ACH Rules and wanting to earn AAP Continuing Education Credits
- Anyone who wishes to enhance their knowledge of the new NACHA Operating Rules
- Audit Departments (within financial institutions) or external Audit Firms
- Third-Party Payment Processors
- Third-Party Senders