When saving your direct deposit information, you will be asked to confirm that you are complying with the Office of Foreign Assets Control (OFAC) requirements as stated below.
If you have questions, please email firstname.lastname@example.org or call 656-6600.
Notice to All Payroll Direct Deposit Participants
As a US entity, the University of Vermont is obligated to comply with the requirements of the United States Department of Treasury Office of Foreign Assets Control (OFAC), which oversees payments sent outside the territorial jurisdiction of the United States. This includes automated clearing house (ACH) payments, such as direct deposits. In accordance with US Treasury department rules that were implemented September 18, 2009, the University is obligated to identify as an “International ACH Transaction” (IAT) any direct deposit of payroll that is (1) made by the University to a financial institution located outside the U.S., or (2) made by the University to a domestic financial institution, if that financial institution immediately transfers the full deposit amount to a financial institution outside of the U.S. in a “back-to-back” transaction.
If you have instructions with your recipient bank to immediately wire the full amount of the direct deposit to a foreign financial institution, we request that you complete the Direct Deposit OFAC Compliance Form (PDF) that provides further detail about the foreign transaction. The form includes instructions on how to complete it and where to send it.
To comply with the OFAC requirements going forward, the University will require that employees confirm, at the time that they elect direct deposit of their net payroll amount, that the direct deposit is being made to a domestic financial institution and that it will not be part of a back-to-back transaction to a foreign institution.