The electronic payments industry has fast become the backbone of the financial services industry. The ACH Network provides a safe, secure, and reliable network for direct consumer, business, and government payments. Annually, this network facilitates billions of Direct Deposits and Direct Payments via ACH. ACH origination volume has increased significantly over the last several years as businesses and consumers take advantage of the broad efficiencies available through the ACH Network. As ACH origination volume continues to grow, FFIEC examiners and ACH auditors have increased their focus on ensuring existing risk management systems and controls adequately address the risks contained within the ACH Network. Moreover, the expansion of organizations originating on behalf of other companies introduces new risk and an increased burden to not only “know your customer” but to “know your customers’ customer”. Failure to implement appropriate controls is viewed as an unsafe and unsound practice which can result in increased credit, compliance, reputation, strategic and transaction risk.
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