
Treasury Management Resources
Important Notice: New 2026 NACHA Fraud Monitoring Requirements
NACHA has announced significant updates to its fraud‑monitoring requirements that will take effect starting March 20, 2026. These changes apply to all organizations that send or receive ACH transactions. The purpose of these updates is to strengthen ACH security, reduce fraud losses and improve the ability to recover funds when fraud occurs.
As fraud schemes continue to evolve – including email compromise, deepfake impersonation, and account takeover attempts – NACHA is requiring a more proactive, risk-based approach to fraud monitoring across the ACH network.
Under the new rules, financial institutions, ACH Originators, Third-Party Senders, and Third-Party Service Providers must implement enhanced fraud detection processes. This is a shift from primarily reactive monitoring to a forward-looking approach designed to catch unusual or suspicious activity before a transaction is processed.
If your organization originates ACH payments—payroll, vendor payments, dues, receivables, or other electronic debits/credits—these rules apply to you.
Key New Requirements for ACH Originators
1. Monitor outgoing ACH transactions for fraud
Your organization must use processes that can identify entries that may be unauthorized or initiated under false pretenses, including fraud schemes such as vendor impersonation, business email compromise, account takeover, and authorized push payment scams.
2. Verify ACH credit recipients using risk-based methods
Before sending ACH credits, you must confirm the receiving account belongs to the intended payee. Verification may include directly confirming account details with the recipient. Documentation of this verification is required.
3. Maintain written procedures and regularly update controls
NACHA requires organizations to maintain audit-ready, documented fraud monitoring procedures, review them at least annually, and update controls as fraud risks evolve.
4. Company Entry Descriptions Update
NACHA requires Company Entry Descriptions to reflect PAYROLL for wages, salaries, & similar types of compensation and PURCHASE for e-commerce.
We value your partnership and are committed to helping your organization achieve full compliance with the 2026 NACHA requirements. Additional correspondence will be sent out soon. If you have any questions in the meantime or would like assistance reviewing your ACH processes, please email your Treasury Management Team at treasurymanagement@citizenslc.com.
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