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Glenn Hegar  ·  Texas Comptroller of Public Accounts

Compliance With U.S. Department of the Treasury Office of Foreign Assets Control Requirements

Issued: Aug. 16, 2004
Updated: May 11, 2012

FPP E.016


Applicable to

State agencies and institutions of higher education


Prohibition on Doing Business With Specially Designated Nationals

On Sept. 23, 2001, President Bush issued Executive Order #13224, “Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism.”

State agencies and institutions of higher education must follow this executive order and not do business with terrorists and terrorist organizations.

The Office of Foreign Assets Control (OFAC) administers this executive order and maintains the Specially Designated Nationals List. State agencies and institutions of higher education are responsible for ensuring they do not issue payments to those individuals or organizations identified in the list.

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, the National Automated Clearing House Association (NACHA) has adopted specific rules regarding International ACH Payments (IATs). NACHA requires entities that originate ACH payments comply with IAT rules and federal law.

In support of the above policies, state agencies and institutions of higher education are 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.

  • Agencies using the Texas Identification Number System (TINS) must follow the procedure outlined in this Fiscal Policy and Procedure.
  • Agencies and institutions that issue payments with local funds need to adopt procedures to demonstrate due diligence with OFAC compliance.
Changes to this Document
05/11/12 Updated to reflect new policy and ACR 28415 – TINS System Change, which required a new name for the FPP.
Glenn Hegar
Texas Comptroller of Public Accounts
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