No, we do not believe that your bank would be able to originate ACH transactions to India. The Federal Reserve’s FedGlobal ACH system allows banks to originate ACH transactions to several countries outside of the U.S., most of them located in Europe, but its services do not extend to India.

To originate ACH payments outside of the FedGlobal system, your bank would need to work through either a “gateway” ACH operator or a financial institution with a correspondent banking relationship in India to process the ACH transactions. We were advised by a consulting firm focused on ACH payments, WACHA, that they are not aware of any gateway operators or financial institutions that would offer ACH services in India. Their recommendation is to continue conducting these transactions as wire transfers.

For resources related to our guidance, please see:

• FedGlobal ACH Payments (India does not appear under “Payment Destinations.”)

• NACHA International ACH Transaction FAQs, page 1 (“8. What is a Gateway? A Gateway can be either an ACH Operator or a Participating Depository Financial Institution, as defined by the NACHA Operating Rules, that acts as an entry point to or exit point from the United States for ACH payment transactions.”)

• NACHA International ACH Transaction FAQs, page 2 (“9. How do I become a Gateway? The term Gateway is a defined term in the NACHA Operating Rules. To become a Gateway a financial institution or ACH Operator must originate ACH entries into or out of the U.S. to other countries. The decision to become a Gateway is a business decision that should be considered by senior management. Some things to consider are establishment of a correspondent relationship in the receiving country; understanding the rules of the receiving country, formatting issues, settlement procedures and a thorough understanding of the risk associated with this business model.”)