What’s up fraud fighters, and welcome back to Fraud Forward!

Today we are talking about ACH compliance, and I know that may not sound like the most exciting opener in the world, but if you work in fraud, payments, operations, compliance, treasury, management, or anywhere near ACH this matters because ACH is one of the most widely used payment rails in the country. And when something goes wrong, it doesn’t just stay contained to one team. It impacts customers, creates operational strain, introduces regulatory risk, and can expose gaps in how your institution detects and responds to fraud.

Over the last few months, I have had conversation after conversation with fraud leaders at community banks and credit unions who are asking the same questions. Do we need new technology? Are we expected to monitor every ACH transaction in real time? What exactly are examiners going to expect from us? And if your head has been spinning a little bit, I want you to hear me on this: you are not alone.

This episode is about the real story behind NACHA Phase 2. And to me, the real story is not that every institution needs to run out and buy another fraud platform. The real story is that ACH compliance is becoming a much more intentional conversation. It is about knowing your risk, documenting your processes, understanding who owns what, and being able to explain why your institution monitors ACH fraud the way that it does.

I actually think that is a good thing. Because for too long, our industry has leaned on liability as the finish line. If we are not liable, it is not really our problem. And technically, maybe sometimes that has been true. But operationally, ethically, and from a fraud fighter perspective, that has never sat well with me.

Fraud does not live in silos. Neither should ACH fraud prevention.

• Why NACHA Phase 2 is about intentionality, not just technology
• What changed in the final Nacha ACH rules and why that flexibility matters
• How ACH compliance applies to community banks and credit unions now in scope
• Why layered controls do not always mean buying another vendor solution
• How false pretenses fit into ACH fraud detection and ACH fraud prevention
• Why RDFI compliance and ODFI compliance require clear ownership across teams
• What examiners may expect when reviewing your ACH compliance program
• Five questions every institution should ask about ACH fraud documentation

• You work in fraud operations, payments compliance, ACH operations, BSA, AML, or treasury management
• Your institution is working through NACHA Phase 2 implementation
• You are trying to understand ACH examiner expectations without overbuilding your program
• You serve a community bank or credit union and need practical ACH compliance guidance
• You want to move from a liability mindset to a visibility mindset in payments fraud

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