NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL FedGlobal® ACH Payments Service Origination Manual Updated October 6, 2022 1 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL Table of Contents Introduction ........................................................................................................................................................ 3 Purpose .............................................................................................................................................................. 3 Document History ............................................................................................................................................... 3 Overview ............................................................................................................................................................ 4 General Description ....................................................................................................................................................... 4 ODFI Compliance Obligations ........................................................................................................................................ 4 RDFI Compliance-Related Inquiries ................................................................................................................................ 5 FedGlobal ACH Payments Compliance ........................................................................................................................... 6 Dodd-Frank 1073 Compliance… ..................................................................................................................................... 6 Risks ............................................................................................................................................................................... 8 Rules Differences ........................................................................................................................................................... 8 Holiday Processing .......................................................................................................................................................... 9 Customer Support.......................................................................................................................................................... 9 Implementation Requirements .......................................................................................................................... 10 Service Request Form .................................................................................................................................................. 10 Pre-production Testing ................................................................................................................................................ 10 FedGlobal ACH Payments Geographic Reach ...................................................................................................... 11 Country/Region Requirements .......................................................................................................................... 12 CANADA ........................................................................................................................................................... 12 MEXICO ............................................................................................................................................................ 19 PANAMA .......................................................................................................................................................... 31 EUROPE ............................................................................................................................................................ 35 Appendix I – IAT Format Origination Matrix ....................................................................................................... 43 Appendix II – IAT Format Origination Matrix / F3X Payments ............................................................................. 52 Appendix III – Guide to a Successful FedGlobal ACH Payments Launch ................................................................ 57 Appendix IV – Mexico F3X Specifications ........................................................................................................... 58 Appendix V – Europe F3X Specifications ............................................................................................................. 59 Appendix VI – FedGlobal ACH Payments ISO Destination Country and Currency Codes........................................ 58 Appendix VII – Instructions for Tracing Payments in Mexico’s SPEI System .............................................................. 61 Appendix VIII – FedGlobal ACH Payments Mexico Service ABM Numbers for RDFIs ............................................. 61 Appendix IX – FedGlobal ACH Payments Panama Service Bank Numbers for RDFIs .............................................. 62 2 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL Introduction FedGlobal ACH Payments is an enhanced suite of international ACH services established to complement FedACH® Services. The portfolio of international ACH services provides a significant increase in the number of countries reachable and payment options available from FedACH. Ultimately, broader country reach, as well as flexibility with payment options allows the Federal Reserve Banks to offer an efficient means of cross-border ACH payments to all originating depository financial institutions (ODFIs). Purpose This manual is intended to assist financial institutions in establishing an international ACH origination program using the Federal Reserve Banks’ FedGlobal ACH Payments Service. The manual will provide an overview of the service, processing, and implementation requirements, as well as country and/or region- specific requirements for the purposes of originating international ACH payments. It is a living document that will be revised as service enhancements are identified and implemented. Your account executive can assist you in implementing a successful international ACH origination program. To determine the appropriate contact, please visit https://frbservices.org/contactus/account- executives.html. This FedGlobal ACH Service Origination Manual should be used in conjunction with Federal Reserve Bank Operating Circular (OC) 4 and the Nacha® Operating Rules. Since these rules may be updated or modified periodically, it is important to retain a current copy for reference. • The Nacha Operating Rules can be referenced for a definition of terms used in this manual. • The Federal Reserve’s Operating Circulars can be obtained by visiting https://frbservices.org/resources/rules-regulations/operating-circulars.html The content of this manual does not in any way constitute legal advice. It is important that ODFIs understand the specific risk and requirements involved in originating payments to foreign countries and should consult with risk management, compliance, and legal staff before originating such payments. Specifically, an ODFI that originates international ACH payments warrant under Additional ODFI Warranties for Outbound IAT Entries of the Nacha Rules that it is in compliance with the laws and payment system rules of the receiving country. Document History October 6, 2022 Updated RDFI bank number listings for Panama in Appendix IX. October 5, 2022 Updated European Payments System Overview the Sweden URL was fixed. September 28, 2022: Updated RDFI bank number listings for Mexico in Appendix VIII. July 1, 2022: Updated RDFI bank number listings for Mexico in Appendix VIII. Removed FedGlobal ACH Formatting Aid references due to decommission on June 30, 2022. December 1, 2021: Updated RDFI bank number listings for Mexico in Appendix VIII. Additional Canadian holiday added. Updated various hyperlinks to outside references. June 1, 2021: Updated to include reference of KYC Questionnaire periodic resubmission. Updated various 3 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL hyperlinks to outside references. Updated Appendix I with notation to include each element of the receiver’s address in order. Updated RDFI bank number listings for Mexico and Panama. 4 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL Overview General Description FedGlobal ACH Payments supports the Federal Reserve’s mission to ensure an efficient, effective, and accessible retail payments system and offers a single processing stream to financial institutions for sending and receiving domestic and international ACH credit and debit1 items using domestic FedACH deadlines. For payments originated in the U.S. and sent through FedGlobal ACH Payments, the Federal Reserve Bank of Atlanta serves as the U.S. Gateway Operator (GO) and works with the appropriate foreign gateway operator (FGO). It is important to remember that each country is governed by its own domestic clearing rules and practices. Some of the prominent differences between the U.S. and foreign country payments systems are highlighted in the appropriate section of the manual to assist you in planning and implementing your service offering. Cross-border payments are formatted using the Nacha Standard Entry Class (SEC) code IAT (international ACH transaction). The Company/Batch Header Record contains information specific to cross-border payments, including data related to foreign exchange, origination and destination country, and currency codes. Consequently, these entries can be included in the same file as domestic ACH transactions but must be batched separately. The IAT SEC code and fields in the Company Batch Header Record allow cross-border payments to be readily identified. For efficiency purposes, ODFIs need to limit their batches to fewer than 500 records. Detailed record layouts are provided in Appendix I and II of this manual. Nacha Operating Rules allow for transactions to be originated in three types of currency value exchange: fixed-to-variable (FV), variable-to-fixed (VF) or fixed-to-fixed (FF). The FedGlobal ACH Payments Service accommodates fixed-to-variable (FV) and/or fixed-to-fixed (FF) for outbound payments destined to foreign countries depending on the agreement with the FGO. These foreign exchange options include: • FV: USD to foreign currency. U.S. dollars are converted to a variable amount of destination currency based on a competitive foreign exchange rate provided as part of the payment flow. • FF: USD to USD. U.S. dollars are both sent and received to USD denominated accounts. This applies to countries that allow USD accounts and are permitted in FedGlobal ACH. • FF: foreign currency to foreign currency. This option, known as F3X2, enables the ODFI to manage its own foreign exchange to participating countries. Settlement is conducted outside of the ACH network through a foreign correspondent. This option requires a separate service enrollment form with the Federal Reserve Banks to be able to participate. FedGlobal ACH Payments also offers the ability to send funds between deposit accounts in the U.S. and destination countries. ODFI Compliance Obligations Federal Reserve Operating Circular 4 applies to all FedACH transactions and contains provisions that apply specifically to all FedGlobal ACH Services. The Nacha Operating Rules apply to all FedGlobal ACH countries to the extent that the Nacha Operating Rules do not conflict with Operating Circular 4. Nacha’s Operating Rules outlines the obligations of Gateway Operators including responsibilities and warranties. 1 FedGlobal ACH Services offers debits to Canada only and does not introduce debits originated from any foreign country. 2 F3X is patented by the Federal Reserve Bank of Atlanta: U.S. Patent No. 7,580,886. 5 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL A GO serves as the entry point to, or exit point from, the United States for payment transactions. A FGO means a gateway operator that acts as an entry point to or exit point from a foreign country. The Nacha Operating Rules allow for flexibility through the U.S. GO/FGO agreement to allocate processing responsibilities, assign warranties and liabilities, establish an accord for the handling of foreign exchange, define settlement procedures, and determine the legal basis for their business relationship. Additionally, U.S. ODFIs are responsible for complying with applicable U.S. law as well as incorporating FedGlobal ACH services into applicable compliance policies and procedures. It is recommended that U.S. ODFIs have the following: a) Have a compliance officer and a compliance program that includes policies and procedures designed to ensure the USODFI’s compliance with the Bank Secrecy Act, and with U.S. laws, regulations, and bank supervisory policies regarding anti money laundering, anti terrorism financing, know your customer, customer identification programs, data security and data privacy, OFAC requirements, and mandatory consumer protections; b) Adopt and adhere to policies and procedures that ensure that all Cross-border transactions are handled in compliance with the USODFI’s compliance policies and procedures, with due regard for the enhanced OFAC requirements for international ACH transactions; c) Perform due diligence with respect to all persons, entities and associated data in every Cross-border transaction to ensure compliance with OFAC regulations, and directly involve the USODFI’s compliance staff in resolving any issues regarding any Cross-border Item that appears as if it may be a prohibited transaction under OFAC regulations; d) Monitor all Cross-border transactions for indications of suspicious activity, including but not limited to structuring such transactions to avoid recordkeeping or reporting requirements or USGO’s limits on transaction amounts; e) File Suspicious Activity Reports and/or Currency Transaction Reports as required by applicable laws or regulations. Information on OFAC regulations can be found at the OFAC web site: http://www.treas.gov/ofac/ and the Nacha Operating Rules. It is important to note that either the GO or the FGO may refuse to handle IAT items originated by any participating U.S. ODFI that they believe poses a compliance risk, such as originating items that include parties on the OFAC list. The quality and accuracy of the information provided by the originator are key to both the ODFI’s and RDFI’s ability to successfully meet compliance obligations. RDFI Compliance-Related Inquiries Financial institutions that receive IAT items that entered the U.S. through FedGlobal ACH may from time to time require additional information about the payment originator. To determine if the IAT item entered the U.S through FedGlobal ACH, the RDFI can cross-reference the ODFI routing number in the E- Payments Routing Directory to verify if the Originating Gateway Operator is part of FedGlobal ACH Payments. By calling the contact number listed, the RDFI will reach FedACH and Check Services Customer Support. The RDFI should state that it is requesting assistance with a compliance-related issue. FedACH will coordinate these inquiries with the Originating Gateway Operating and will make reasonable efforts to facilitate initial communication between the depository financial institutions on both ends of the IAT item. 6 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL FedGlobal ACH Payments Compliance While cross-border ACH is inherently riskier than ACH payments made between counterparties within the United States, U.S. laws and regulations provide guidance to ODFIs on carrying out cross-border payments in a compliant manner. As an originator of IAT items outside the United States on behalf of U.S. ODFIs, FedGlobal ACH Payments seeks to support regulatory compliance by carrying out a series of compliance-related activities. The Federal Reserve Bank of Atlanta, the U.S. Gateway Operator for FedGlobal ACH Payments, maintains a compliance officer and compliance program aimed at ensuring that payments transacted over the FedGlobal ACH service are compliant with U.S. laws and regulations. The objective of the compliance program is to: 1) detect attempts to abuse the Federal Reserve Banks’ FedGlobal ACH services for money laundering; 2) prevent such abuse; and 3) report the attempted abuse to the requisite authorities. The Federal Reserve Bank of Atlanta’s compliance program includes: 1) transaction monitoring for Anti- Money Laundering and OFAC compliance at the aggregate level; 2) transaction monitoring for limits on the payment value by originator, where applicable; 3) establishing compliance obligations for payment processing in agreements with gateway operators and third-party service providers; and, 4) due diligence reviews of service offerings that include evaluations of gateway operators and third-party service providers as well as country risk assessments. Transaction monitoring for Anti-Money Laundering may include post processing reviews of payments by ODFI, RDFI, originator, country of destination and origin, concentrations of payment activity and unusual patterns of activity. U.S. regulatory authorities will be notified of potentially suspicious payment activity. OFAC monitoring is conducted on items entering the U.S. ACH network through FedGlobal ACH Payments as requested by OFAC and the RDFI and OFAC are notified of potentially suspicious items. The transaction monitoring is conducted on a post transaction basis because FedACH as an ACH operator cannot separate out or pend suspicious items on a flow-through basis. As a gateway operator, the Federal Reserve Bank of Atlanta includes in each FedGlobal ACH Payments agreement with processors and Foreign Gateway Operators requirements that processors and Foreign Gateway Operators: 1) have a compliance officer; 2) establish and follow compliance policies and procedures; 3) be FATF compliant; 4) follow applicable record keeping requirements per local laws; and 5) follow applicable reporting requirements on illegal or suspicious transactions/activities per local laws. Due diligence activities also include a risk assessment of the foreign gateway partners and any third-party service providers involved in carrying out the service, a country risk assessment of the countries which receive, or which may originate payments into FedGlobal ACH Payments. The counter-party risk assessment evaluates operational risks, service level risks, and overall compliance risk. The country risk assessment evaluates risks presented the country or countries reached. Identified risks have been documented and mitigation procedures have been put in place. As examples, risk mitigation measures would include transaction monitoring and stipulations in legal agreements. The service offerings provided by FedGlobal ACH Payments have successfully met the criteria established by the Federal Reserve Bank of Atlanta’s compliance program. Dodd-Frank 1073 Compliance In 2013, the Consumer Financial Protection Bureau (CFPB) implemented Section 1073 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank 1073). The rule, which amends Regulation 7 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL E, focuses primarily on disclosure, error resolution, and cancelation requirements for remittance transfer providers facilitating outbound cross-border consumer initiated electronic transfers of funds. Dodd-Frank 1073 establishes requirements for exact disclosures in most cases. However, estimated disclosures are allowed under certain circumstances. Effective July 21, 2020, the CFPB amended Regulation E pertaining to certain protections for consumers sending U.S. outbound international money transfers or remittance transfers (“Remittance Rule”). The Regulation E amended provisions on U.S. outbound cross-border transactions only pertain to consumer remittances and have no impact on non-consumer payments (i.e., business, corporate, government). The FedGlobal ACH Payments can still be used for these transactions. The following highlights the amended provisions. • Increase in safe harbor threshold from 100 to 500 transfers annually • New, permanent exception that permits insured institutions to estimate the exchange rate for a remittance transfer to a particular country if, among other things, the designated recipient will receive funds in the country’s local currency and the insured institution made 1,000 or fewer remittance transfers in the prior calendar year to that country when the designated recipients received funds in the country’s local currency • New, permanent exception will permit insured institutions to estimate covered third-party fees for a remittance transfer to a designated recipient’s institution if, among other things, the insured institution made 500 or fewer remittance transfers to that designated recipient’s institution in the prior calendar year The Regulation E amended provisions may have potential impacts for certain FedGlobal ACH Payments subscribers. The most prevalent of these pertains to responsibilities of institutions to provide exact foreign exchange (FX) disclosures. Although FedGlobal ACH Payments does not support exact FX disclosure for consumer remittances requiring US dollar to local currency conversion, institutions should consult with their legal, compliance, or supervisory authority to assess the impact of the amended provisions and when FedGlobal ACH Payments can be used. In consideration of guidelines in the final rule for the safe harbor threshold and number of remittances transferred in the prior year, the following FedGlobal ACH Payments - FX Disclosure Matrix for Consumer Remittances has been provided to assist subscribers with assessing when FedGlobal ACH Payments can be used for consumer remittances. 8 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL With FedGlobal ACH Payments, financial institutions are enabled with information around foreign fees, foreign taxes, and the date of funds availability, as well as estimated foreign exchange rates. Additionally, the service bolsters error resolution by assisting with the tracing of transactions where an error has occurred. Customers should consult their legal/compliance department to determine whether their institution is able to use estimates and how the information provided by the FedGlobal ACH Payments service can help satisfy disclosure obligations. Risks Federal Reserve Operating Circular 4 and the Nacha Operating Rules stipulate the rights, obligation, and warranties with respect to the U.S. payments system. Differences in the U.S. and foreign country payments systems may pose operational risk to an ODFI. Credit risk also exists with respect to return items, including but not limited to the following example: • Return timeframes may be extended due to differences in country regulations, causing the originator to absorb extended temporal foreign exchange (FX) currency exposure and extended temporal credit risk of unsuccessful return charge back. Originators should also note that a different FX rate can be applied to the originated item and the return. This difference varies by the destination currency and country. • Financial institution accounts are denominated in a particular currency. It is the responsibility of the ODFI and originator to determine the currency that the receiver’s account is denominated in and to properly format the IAT fields. Otherwise, there is the potential that if the receiving depository financial institution receives a cross-border ACH item denominated in the incorrect currency, the receiving depository financial institution may convert the item into the appropriate currency and post the item to the receiver’s account, instead of returning the item back to the foreign gateway operator. This is generally the case if there is a standing agreement between the receiving financial institution and its customer to provide the foreign exchange conversion. However, this not a requirement in some destination countries. This foreign exchange conversion is outside the scope of the FedGlobal ACH Payments service. If the receiving depository financial institution does return the item, the foreign exchange rate used does fall under the FedGlobal ACH Payments service. Ultimately, it is important for the ODFI to work with the originator to determine the appropriate destination currency related to the receiver’s account. Rules Differences As noted earlier, the Federal Reserve Banks and the appropriate FGO serve as conduits to their domestic payment systems to process and deliver international ACH payments. ACH items originated in the United States are governed by U.S. laws and rules (including the Nacha Rules), until they cross the border into another country. Once they arrive in the foreign country, foreign country local laws and rules apply. Examples of rule differences include but may not be limited to the following: • Different return time frames by country. • Debit authorization requirements for Canada. • Ability to hold local (destination) currency and/or U.S. dollar currency accounts. • Regulatory requirements in foreign countries vary. The IAT format enables all participating U.S. financial institutions to provide the necessary and regulatory compliant information in the appropriate fields to be delivered to receiving financial institutions in foreign countries. If the 9 NNOONNCCOONNFFIIDDEENNTTIIAALL //// EEXXTTEERRNNAALL information provided in the IAT fields is inaccurate or non-specific, the foreign gateway operator and/or the receiving financial institution may find it necessary to return the item. Therefore, it is important for the originating financial institution to work with the originator to be able to accurately format as well as provide quality information in the IAT records. Prenotifications and Notifications of Change (NOC) Prenotes are only supported to Panama. NOCs are only supported to Canada and Panama. To verify account information for a new receiver, a forward IAT credit for $2.00 may be sent. If the information for the receiver is incorrect, the receiving financial institution may return the item within the appropriate time frame for the receiving country. ODFI Recalls and Reversals Reversals are not supported in FedGlobal ACH Payments. If an error is detected after a file has been submitted, the U.S. ODFI should contact the originator, which in turn should work with the receiver to request a refund of the duplicated funds. In addition, the U.S. ODFI can contact FedACH, who can provide contact information for the foreign RDFI. Please refer to the Customer Support section for FedACH and Check Services Customer Support contact information. The U.S. ODFI and/or originator are responsible for contacting the foreign RDFI or the beneficiary to request a refund of the item. Holiday Processing Foreign country banking holidays are not identical to U.S. banking holidays. ODFIs occasionally transmit items through FedACH for settlement on a foreign country banking holiday. When this occurs, FedACH will process the items, send to the FGO, and settle against the ODFI’s settlement account on the specified settlement date. The FGO will process, deliver, and settle the items to the foreign receiving financial institutions on the next banking day after the holiday. For payments that require a foreign exchange rate conversion, the foreign exchange rate applied will be the date of the foreign settlement date, which may be different than the U.S. settlement date. For a list of the foreign country’s holidays, please refer to the following URL for a list of bank holidays throughout the world: http://www.bank-holidays.com/index.htm Supplementary holiday schedules for FedGlobal ACH Payments participating countries may be found in the appropriate section of the manual. Customer Support ODFI Item Trace To initiate an item trace on a FedGlobal ACH Payments transaction, U.S. ODFIs should contact FedACH and Check Services Customer Support. The Federal Reserve Banks will work with the appropriate FGO to answer inquiries and a response should be provided within 3 business days. Transactions in amounts less than $20.00 may not be traced beyond FedACH (the U.S. GO) for FedGlobal ACH Payments. It is important to note that U.S. ODFIs are responsible for any investigation fees should they be assessed by foreign RDFIs or downstream payment participants. 10