Automating Nacha’s Risk-Based Processes

by Ashley Poynter

Content Manager

Automating Nacha’s Risk-Based Processes for Proactive Fraud Detection

Organizations are facing a growing wave of sophisticated fraud, and relying on compliance alone just doesn’t cut it anymore. With Nacha’s Risk-Based Processes set to change in 2026, there’s a clear shift happening: instead of cleaning up after fraud happens, the focus is now on stopping it before it starts.

Starting June 22, 2026, all non-consumer ACH participants will be expected to take a more active role in detecting fraud. If your organization sends or receives ACH payments, now’s the time to rethink your approach to fraud monitoring, and automation will be key to keeping up.

In this piece, we’ll unpack what Nacha’s Risk-Based Processes actually require, why automation is quickly becoming essential, and how you can start building a monitoring strategy that’s both scalable and compliant.

What Are Nacha’s Risk-Based Processes?

Why Manual Detection Methods Fall Short

What Automation Enables That Manual Monitoring Cannot

Applying Nacha’s Risk-Based Processes Across Roles

The Emerging Risk of False Pretenses Fraud

Building an Automated Risk-Based Process

Preparing for June 2026. Why Start Now?

Proactive Compliance is Smarter Compliance

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What Are Nacha’s Risk-Based Processes?

Let’s break it down. Nacha’s Risk-Based Processes are a new set of requirements that ask all non-consumer ACH participants (Originators, Third-Party Service Providers (TPSPs), Third-Party Senders (TPSs), ODFIs, and RDFIs) to implement fraud detection processes that make sense for their role and transaction types.

The key idea? There’s no one-size-fits-all checklist. Instead, the rules focus on a few critical principles:

Ongoing monitoring based on the nature of the transactions
Custom processes that reflect your organization’s transaction volume and vendor makeup
An annual review of your fraud detection approach to ensure it stays effective

The main goal is to reduce fraud across the ACH network, especially those schemes that rely on false pretenses, like business email compromise (BEC), vendor impersonation, or unauthorized account takeovers.

Think of it like this: your fraud monitoring process should be designed to catch red flags before money ever moves. It’s similar to anti-money laundering (AML) frameworks in that it calls for continuous monitoring, but it’s flexible enough to adapt to your organization’s specific risk profile.

Why Manual Detection Methods Fall Short

Despite growing fraud risks, many organizations are still leaning heavily on manual workflows to flag questionable activity: email chains, spreadsheets, static PDFs, or even a single person’s institutional knowledge. These approaches might feel manageable at a small scale, but as vendor ecosystems grow and fraud tactics evolve, the cracks in the system become too wide to ignore.

Manual processes often:

Lack consistency and auditability, so it’s hard to prove that controls were followed
Struggle to keep up with increasing transaction volume and velocity
Are prone to human error, especially under pressure or time constraints
Provide no real-time visibility, causing delays in identifying red flags

Fraudsters know this. Fraudsters exploit it. Email-based vendor impersonation, fake bank updates, and social engineering scams slip through the gaps of fragmented, manual processes.

It’s no coincidence that Nacha’s 2026 update removes “commercially reasonable” as the compliance benchmark. They’re raising the bar. You can’t simply show you tried. You have to prove your processes are effective, consistently applied, and designed to stop fraud before it succeeds.

What Automation Enables That Manual Monitoring Cannot

Here’s the good news: automation helps you comply with Nacha’s Risk-Based Processes and empowers you to do it better, faster, and more securely. Where manual reviews fall short, automation can bring scale, speed, and precision.

With automation, organizations can:

Monitor inbound and outbound ACH transactions in real time, rather than after the fact
Detect behavioral anomalies based on transaction history and vendor baselines
Automatically validate identity and banking data before initiating a payment
Flag suspicious patterns, like unusual velocity, mismatched SEC codes, or newly changed banking info
Maintain clear, timestamped logs of every review and decision for audit readiness

The flexibility of automation is just as important as the power. As your vendor base grows or new fraud patterns emerge, your monitoring logic can evolve so you don’t need to rebuild the wheel every time.

And most importantly, automation shifts your approach from reactive to proactive. Instead of hoping you catch fraud in the rearview mirror, you’re building a system that raises the alarm before the money leaves the building.

Applying Nacha’s Risk-Based Processes Across Roles

For Originators, TPSPs, TPSs, and ODFIs

Beginning June 22, 2026, organizations that initiate ACH payments—including Originators, TPSPs, TPSs, and ODFIs—will be required to take ownership of detecting fraud through robust, risk-based procedures. This isn’t just a compliance checkbox; it’s a mandate to take a closer, smarter look at every transaction your organization pushes into the ACH network.

Key actions include:

Establishing a baseline of typical activity for each vendor or partner
Continuously monitoring for spikes in transaction frequency, unexpected changes in account information, or mismatches in SEC codes
Relying on validated, trusted sources when processing any banking information updates
Conducting annual reviews to ensure fraud monitoring procedures stay relevant and effective

Automation makes it possible to segment transactions based on risk, enforce real-time anomaly detection, and ensure repeatable, reviewable controls are consistently followed. These tools support compliance while helping institutions avoid becoming fraud statistics.

For RDFIs

Receiving institutions also play a critical role in Nacha’s fraud prevention strategy. RDFIs have unique visibility into account behaviors, making them key players in catching fraud that may have slipped through earlier stages.

To comply with Nacha’s Risk-Based Processes, RDFIs are expected to:

Implement systems that monitor account activity for unusual patterns, especially around high-value ACH credits
Identify discrepancies, such as SEC code mismatches or transfers into newly opened or dormant accounts
Connect fraud alerts with internal teams, ensuring operations, product, and compliance staff are working from the same playbook

With automation, RDFIs can set thresholds, surface red flags, and create audit-ready logs of how decisions are made. More importantly, these processes can run continuously in the background to ensure no suspicious transaction is missed.

The Emerging Risk of False Pretenses Fraud

Among the biggest threats highlighted by Nacha’s rule update is fraud executed under “false pretenses,” where fraudsters manipulate trust, impersonate vendors or internal stakeholders, and redirect payments without triggering technical alarms.

These attacks are subtle, well-researched, and often impossible to detect with manual systems alone.

Common examples include:

Impersonated vendor emails requesting banking updates
Fraudsters posing as payroll providers to redirect employee payments
Requests accompanied by forged documentation that appears legitimate

What makes false pretenses fraud especially dangerous is its ability to bypass traditional verification steps.

That’s why Nacha’s Risk-Based Processes emphasize layered verification. This means looking beyond account details to verify identity, role, and ownership. Automation allows you to enforce these steps consistently, across all transactions, without relying on memory or inboxes.

Building an Automated Risk-Based Process

Designing a scalable, automated, Nacha-compliant fraud detection system is about building an ecosystem of proactive controls. Here’s where to start:

Mapping Risk: Understand where your ACH process is most vulnerable: during onboarding, account updates, recurring payments, or approvals.
Segmenting Vendors or Payees: Classify third parties based on transaction patterns, business type, or geography to tailor risk detection.
Automating Validation: Embed steps like TIN matching, OFAC screening, and bank ownership checks directly into your workflows.
Setting Thresholds: Use transaction data to define what’s “normal” and flag what’s not, based on volume, timing, or account history.
Logging and Review: Ensure every transaction review and escalation is captured, timestamped, and attributable for audit readiness.
Cross-Team Visibility: Break down silos by connecting compliance, finance, and operations through shared access to fraud detection insights.

Automation isn’t about replacing people; it’s about empowering your teams with smarter tools, eliminating the guesswork, and turning risk mitigation into a daily habit. With the right tools and training, automated fraud detection becomes a competitive advantage.

Preparing for June 2026. Why Start Now?

Yes, June 2026 might feel far away, but in implementation terms, it’s just around the corner. Starting now gives your team time to:

Identify gaps and pain points in current fraud prevention processes
Test and iterate on automation workflows before they’re mandatory
Train staff on new protocols, escalation paths, and monitoring tools
Reassess vendor onboarding practices to ensure they align with the new rules

Compliance with Nacha’s Risk-Based Processes is a mandate and a milestone in your organization’s maturity around fraud prevention. Getting ahead of the curve means fewer surprises, stronger defenses, and a much smoother path to audit readiness.

Proactive Compliance is Smarter Compliance

Nacha’s 2026 rule changes serve as a signal that the landscape of fraud prevention is shifting, and organizations must adapt accordingly. Manual, reactive strategies are no longer sufficient in the face of increasingly sophisticated fraud tactics.

A proactive approach to Nacha’s Risk-Based Processes means putting systems in place that identify threats before a payment is initiated. It’s about detecting unusual activity early, investigating quickly, and keeping fraudulent transactions from slipping through the cracks. By embedding these processes into automated workflows, organizations not only reduce risk but also build repeatable, auditable practices that scale with growth.

The June 2026 deadline is coming. But for organizations that act now, Nacha’s Risk-Based Processes are an opportunity to lead, to improve, and to build a smarter, more resilient foundation for secure ACH operations.

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