FMX Home
Glenn Hegar  ·  Texas Comptroller of Public Accounts

Foreign Asset Control Requirements
Prohibition on Direct Deposit to Financial Institutions Outside the U.S.

OFAC requires that all direct deposit payments transmitted outside the United States be identified and monitored. In addition, NACHA has adopted specific rules regarding International ACH Payments (IATs). For a helpful introduction, see the IAT Tutorial.

Your agency is responsible for ensuring that the direct deposit payments issued to accounts at U.S. financial institutions are not being transferred to financial institutions outside the U.S.

  • The International Payments Verification section on the Direct Deposit Authorization forms asks payees to indicate if their payments will be forwarded to a financial institution outside the U.S.
  • When a payee answers yes in this section, agencies must not set up direct deposit information in TINS.
  • Agencies should have the payee complete the ACH (Direct Deposit) Payment Destination Confirmation form (74-227) (login required) PDF to determine if they can move forward with direct deposit or not. If the payee does not complete the additional form, agencies are responsible for providing it to the payee for completion.

    Note: Agencies must maintain copies of the completed ACH (Direct Deposit) Payment Destination Confirmation forms to demonstrate due diligence with OFAC compliance.

  • If payees confirm on the form that 100 percent of their direct deposit payments are destined outside the U.S., enter Y in the IAT IND field on the
  • When this indicator has been added or changed, the Payee Maintenance History (PMTHIS) screen will display Add/Chg IAT Ind.
  • To delete the indicator, delete the Y for a blank field.
  • All paying agencies should take note if the IAT indicator is Y and contact the payee to confirm the payment destination.

Note: Each agency is responsible for maintaining the IAT IND field for their payees and ensuring there is no indication that payees intend to transfer direct deposit payments outside the U.S. If there is any doubt, the agency should contact the payee before setting up direct deposit information to ensure that the agency’s payments will remain in the U.S.

Glenn Hegar
Texas Comptroller of Public Accounts
Questions? Contact
Comptroller.Texas.Gov | FMX
FMX Sitemap | Contact FM
Accessibility Policy | Privacy and Security Policy