[September 21, 2009]

The 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 direct deposits. Effective September 18, 2009, the University is obligated to identify as an "International ACH Transaction" (IAT) any direct payroll deposits 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, the University will require that employees confirm, at the time that they request direct deposit of their payroll checks be set up, that the direct deposit is being made to a domestic financial institution and will not be part of a back to back transaction to a foreign institution.

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