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IAT and TINS IAT Indicator Tutorial

State Agency Responsibility

To ensure compliance with OFAC requirements and avoid potential federal penalties, the responsibility starts with each state agency, including institutions of higher education. Each state agency must:

  • Be able to demonstrate due diligence in the processing of all its direct deposit payments.
  • Do its best to ensure the direct deposit payments it issues to accounts at U.S. financial institutions are not being transferred to financial institutions outside the United States.

Know your customer (payee) and perform the proper research before allowing the payee to be set up for direct deposit payments.

  • Make sure your payee is not listed on the Specially Designated Nationals (SDN) List. State agencies are prohibited from doing business with individuals and entities on this list. For more on the SDN List, see the Foreign Asset Control Requirements section of TexPayment Resource.
  • Ensure all payees who request their payments by direct deposit provide the appropriate direct deposit authorization form with the IAT question answered and the form signed. A direct deposit authorization form should not be processed if the IAT section is left blank or if the form is unsigned.

Agencies and institutions of higher education that issue direct deposit payments from local funds must implement procedures to demonstrate due diligence for OFAC compliance. If payees have questions about OFAC requirements, direct them to their financial institutions.

Next: Authorization Forms