How we structure an auditable Wire / ACH / LC payment path.
From OFAC screening to FinCEN-ready documentation, here is how we keep every outbound payment to your overseas or domestic supplier traceable and defensible.
Map your payment landscape
How many suppliers, which channels (Wire/ACH/LC), which currencies, and which thresholds trigger CTR or 8300? We start with a 30-minute scoping call to size the work.
Verify recipient & screen OFAC SDN
Before any USD leaves the account we verify beneficiary bank, ABA/SWIFT/IBAN, business registration, and run OFAC SDN + Consolidated Sanctions screening on the vendor and the beneficiary bank.
Trigger compliance thresholds
We flag FinCEN CTR (>$10K cash equivalent), SAR review (≥$5K suspicious), Form 8300 (cash trade/business), FBAR aggregate, and 1099-NEC obligations — before they become a backdated filing.
ISF 10+2 + UFLPA evidence gate
For imports we hold the Wire/ACH until ISF 10+2 and UFLPA supply-chain declaration are uploaded. No evidence, no release — the gate is enforced, not advisory.
Release with full IMAD/MT103 trace
Funds move with Fedwire IMAD or SWIFT MT103 reference captured to the payment record. You see exactly where the money went, who received it, and the compliance trail behind it.
Recurring coordination & filings
For PO programs we keep the OFAC re-screen cadence, CTR/8300 filings, FBAR year-end aggregate, and 1099-NEC roster aligned — quarter after quarter.
Why US importers need a structured payment path
US compliance touchpoints we cover
Vendor + beneficiary bank, re-screened on every Wire
Cash-equivalent >$10K, filed within 15 days
Suspicious activity ≥$5K, 30-day window
Trade/business cash >$10K from one buyer
Foreign accounts aggregate >$10K, annual
US payees ≥$600/yr, January filing
Coverage is structural — not a guarantee. Filing obligations remain with the US importer of record.