WASHINGTON-CUNA and NAFCU have presented a united front on NACHA's-the Electronic Payments Association's -proposal regarding International Automated Clearinghouse (ACH) Transactions related to amendments made by the Office of Foreign Asset Control. Both groups supported the NACHA alternative to expand the definition of International ACH Transaction to include all cross-border ACH transactions whether initiated through the Gateway Operator or a financial institution, but it still needs some major work. NAFCU wrote, “While the proposal defines what is meant by the term “international ACH transaction,” NAFCU is concerned that it does not sufficiently define the operating principle of the definition, namely, what or who is a party “not subject to U.S. legal jurisdiction”. NAFCU believes that the proposed definition should be modified so that a participant can use it to determine a party's jurisdictional status (subject or not subject to U.S. law) with certainty.” “CUNA believes the proposed definition may unintentionally sweep domestic transactions under these requirements,” CUNA's letter offered. CUNA and NAFCU both recommended delaying the implementation date from March 16, 2007 to September 2007, among other changes.