Approving automated clearing house (“ACH”) payments for processing by an ACH operator is based on an approved originator list identifying originators authorized by an originating depository financial institution (“ODFI”) to originate ACH payments and to send those ACH payments to the ACH operator on behalf of the ODFI. The ACH operator receives an ACH payment originated by a first originator and sent to the ACH operator on behalf of the ODFI. The ACH operator determines whether the first originator is on the approved originator list and processes the ACH payment if the first originator is on the approved originator list. The ACH operator can reject the ACH payment if the first originator is not on the approved originator list or can seek approval from the ODFI to process the ACH payment even if the first originator is not on the approved originator list.