Effective September 18, 2009, the United States Department of Treasury Office of Foreign Assets Control (OFAC), which oversees payments sent outside the territorial jurisdiction of the United States, requires the University to identify as an "International ACH Transaction" (IAT) any direct payroll deposits that UC makes to:

  1. A financial institution located outside the U.S., or
  2. A domestic financial institution if that financial institution immediately transfers the full deposit amount to a financial institution outside the U.S. in a "back-to-back" transaction.

These include automated clearinghouse (ACH) payments, such as direct deposits. UC Retirement System (UCRS) rules do not permit direct deposits of UCRP payments to banks outside of the United States. However, if you have instructed your recipient bank to immediately wire the full amount of the direct deposit of your UCRP monthly benefit to a foreign bank, you must complete the UCRS OFAC Compliance Form that provides further details about the foreign transaction.