This webinar training reinforced that ACH risk assessments shouldn’t be “check-the-box” exercises to satisfy examiners. Instead, the focus is shifting toward:
Risk assessments must be living documents that directly inform controls, procedures, and monitoring.
Auditors and regulators are looking for evidence of how risk assessments feed into actual practice—not just completion.
Risks need to be broken down by:
Originators, SEC codes, exposure limits, return activity, and volume.
External vendors, third parties, APIs, and file transfer processes.
High-risk entities (e.g. same-day ACH originators, third-party senders) should trigger specific due diligence and monitoring.
Internal ACH risk scoring, trend analysis, and reporting must be tailored for operations, risk officers, and executive-level decision-makers.
ACH risk programs must intersect with enterprise risk frameworks, vendor management, and fraud programs.
Automation and dashboards were recommended for:
Real-time risk identification
Tracking action plans tied to assessment findings