International ACH Transactions (IAT)
This set of Rules includes two amendments: Optional Date of Birth Field for IAT Entries and Non-Bank Foreign Financial Agencies in IAT Entries.
These new Rules align with Nacha’s strategies and objectives for the ACH Network to improve the ACH user experience, increase awareness and understanding of ACH capabilities, and improve data flows for ACH payments.
Details
Optional Date of Birth Field for IAT Entries
This rule will designate an optional field for the known Date of Birth (DoB) of a natural person sender and/or receiver of an IAT Entry.
Industry participants report that the most requested piece of information to resolve IAT exceptions is the Date of Birth for the party identified as a potential match in compliance screening.
Industry input indicates that potentially 20% of received IATs must be reviewed manually for potential matches.
Date of Birth information within the ACH Entry will be covered by current ACH Network data security requirements. This may be more secure than sharing this information through means outside of the ACH Network.
In June of 2025, the Financial Action Task Force (FATF) issued an update to its Standards on Recommendation 16 on Payment Transparency that would require cross-border payments over a de minimis amount to include the date of birth for natural person originators. This rule change aligns the ACH Network with the FATF recommendation.
Other capabilities support the exchange of information related to IAT exceptions.
Nacha’s Risk Management Portal includes a secure module for an FI to request information from another FI in order to process an IAT Entry exception.
Nacha’s ACH Contact Registry currently includes the ability to voluntarily list IAT/OFAC-related contacts.
Non-Bank Foreign Financial Agencies in IAT Entries
This rule will expands several field descriptions that identify the Originating and Receiving DFIs in an IAT Entry to recognize the possibility that the financial agency outside the U.S. is a non-traditional account-holding institution or organization.
- Expands existing references to bank or financial institution to include a generic reference to financial agency.
- Incorporates an “other” option in the types of codes used to classify the financial agency’s identification number.
This rule will not affect the receipt of inbound IATs, which must continue to be received by domestic RDFIs, and does not apply to domestic ACH transactions.
Technical
Optional Date of Birth Field for IAT Entries
This amendment will become effective March 19, 2027.
Reserved space in the addenda records will be allocated for the optional inclusion of the DoB for the sender, receiver, and, for split transactions, the ultimate beneficiary or payor.
The fields will be designated as Optional for use by the Originator (that is, not edited by ACH Operator.
Appendix Three, SUBPART 3.1.12 - Sequence of Records for IAT Entries
- This change re-purposes currently-reserved spaces 74-83 within the Third and Seventh IAT Addenda Records.
Appendix Three, SUBPART 3.2.2 - Glossary of Data Elements
- Adds Originator Date of Birth and Receiver Date of Birth to the listing of data elements.
- Updates Payment Related Information to permit the inclusion of Date of Birth for the ultimate beneficiary or payor.
Appendix Four, SUBPART 4.3.6 – Sequence of Return Records for IAT Entries
- This change re-purposes currently-reserved spaces 74-83 within the Third and Seventh IAT Addenda Records.
Non-Bank Foreign Financial Agencies in IAT Entries
This amendment will become effective March 19, 2027
This rule will expand the following field descriptions to accommodate the identification of foreign non-traditional account holding institutions in an IAT Entry:
Appendix Three Subpart 3.2.2 (Glossary of Data Elements):
Descriptions of these fields will be expanded to include generic references to “non-bank foreign financial agency“ and clarify field usage for inbound, outbound, and IAT Entries that “pass-through” (funded outside of and subsequently again leave) the United States, as appropriate:
- Foreign Correspondent Bank Branch Country Code
- Foreign Correspondent Bank Identification Number
- Foreign Correspondent Bank Name
- Originating DFI Branch Country Code
- Originating DFI Identification
- Originating DFI Name
- Receiving DFI Branch Country Code
- Receiving DFI Identification
- Receiving DFI Name
This rule will expand the following field descriptions to accommodate the identification of a foreign non-traditional account holding institution in an IAT Entry, continued:
Appendix Three, Subpart 3.2.2 (Glossary of Data Elements)
Receiving and Originating DFI and Foreign Correspondent Bank Identification Number Qualifier 2-digit code values would be supplemented with an alternative organization type: ("Non-Bank Foreign Financial Agency Identifier”.)
- Note: The existing identifier value "03 IBAN" and references to that value will be deleted. Because IBAN identifies an account number format rather than a financial institution numbering scheme, it does not apply to these fields.
The Originating DFI Identification description will also be updated for Inbound IAT Entries to remove the reference to National Clearing System Number and replace it with “identification number.”
Impact
Optional Date of Birth Field for IAT Entries
Anticipated Benefits
Originators, TPSPs/TPSs and ODFIs:
- Populating a party’s date of birth, when possible, within the IAT record should reduce the number of inquiries received from RDFIs requesting this information to resolve a potential compliance scanning match.
RDFIs:
- Receiving a party’s date of birth, when possible, within the IAT record should reduce the number of inquiries needing to be made to request this information to resolve a potential compliance scanning match. RDFIs have indicated this is the #1 data element requested to resolve exceptions.
All Participants:
- While FATF recommendations are non-binding on U.S. entities unless and until adopted by U.S. authorities (e.g., U.S. Treasury), should the “Travel Rule” be amended as a result of the updated FATF recommendations, the ACH Network and participants would be well positioned to be in compliance.
Potential Impacts
For Originators, TPSPs/TPSs and ODFIs:
- Determination and implementation of policies and procedures related to date of birth collection, where appropriate.
- Assessment of data security measures for DoB information.
- System updates to generate revised IAT format.
- Originators should not populate the field with DoB prior to the effective date of the proposed Rule.
For RDFIs:
- System updates to receive revised IAT format.
- Training/Procedure updates to locate information, when populated.
- Assessment of data security measures for DoB information.
For ACH Operators:
- System updates to process revised IAT format.
Non-Bank Foreign Financial Agencies in IAT Entries
Anticipated Benefits:
Originators, TPSPs/TPSs and ODFIs:
- Ability to originate outbound IATs to non-traditional accounts, if desired.
RFIs:
- Potential receipt of IATs from new sources (or more accurate description of existing sources) on behalf of account holders.
Potential Impacts:
Originators, TPSPs/TPSs and ODFIs:
- Review of current processes, if applicable, and potential programming updates to enable use of non-traditional accounts in IATs (if desired).
RDFIs:
- None anticipated.
