Q2 NPG Client Town Hall - Beyond ACH

Beyond ACH: Strengthening Originator, Third-Party, and BSA/AML Due Diligence

Financial institutions are facing increasing scrutiny around their oversight of Originators and Third Parties, particularly as expectations continue to evolve across both ACH compliance and BSA/AML risk management.

Through our work across the industry, we consistently see institutions struggling to define what due diligence is truly relevant, how to assess its sufficiency, and how to address gaps—especially when Third-Party Senders and other Third-Party relationships lack appropriate audit coverage or well-developed control frameworks. These challenges are not only creating internal uncertainty but are also resulting in Rules violations and broader compliance exposure.

At the same time, many of these gaps extend beyond ACH and into BSA/AML programs. Institutions are often challenged to fully understand the nature and purpose of customer and Third-Party activity, appropriately calibrate monitoring and escalation processes, and ensure independent testing meaningfully evaluates higher-risk areas. As transaction volumes and third-party relationships grow—particularly in complex payment environments—these weaknesses can compound if not proactively addressed.

In this Q2 Town Hall, we will focus on leading practices for originator and TPS due diligence through both an ACH and BSA/AML lens. We will share practical insights on what effective due diligence looks like, how to better align documentation and review processes to actual risk, and approaches to addressing common deficiencies—particularly around audit validation, ongoing monitoring, and developing a more complete understanding of Third-Party activity.