12 Jul
02 Feb

How State Regulators View TPPPs

When you say Third-Party Payment Processor (TPPP) or Know Your Customer (KYC) supervision, most US banks think first of prudential regulators. In particular, the Office of the Comptroller of the Currency (OCC) oversees nationally chartered banks and…

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10 Dec
06 Oct
20 Aug

Could You Be Facilitating Fraud?

Last week we had the opportunity to attend the Merchant Acquirer Committee’s regional conference in Los Angeles, where I was impressed by the quality and depth of the information presented.

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04 Aug
21 May

Do You or Don’t You Derisk? The UK Has a Message US Banks May Heed

In a practice referred to as “derisking,” banks have been avoiding customer classes with a higher propensity for money laundering and terrorist financing activity. But as certain business types like charities, remittance facilitators, crypto-currencies, and other money service businesses (MSBs) lose access to banking altogether, regulators are trying to course-correct.

The FDIC backtracked from initial guidance to avoid certain classes of customers. As stated in FIL-5-2015:

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