27 Oct
12 Jul
11 Feb

BSA/AML Compliance for Marijuana Businesses

Numerous states — 23 and counting — have legalized distribution of medicinal and recreational marijuana. A growing number of cannabis businesses seek access to financial institutions (FIs). How should banks approach this opportunity?

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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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08 Dec

Common Gaps in BSA/AML Programs Today

At last month’s American Banker’s Association Money Laundering Enforcement Conference in Washington, DC, I attended a session where a representative from the OCC discussed the most common gaps in financial institutions’ BSA/AML programs that led to

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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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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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05 May

9 Years and Counting, OCC Guidance on ACH Still Points the Way

Recently, I listened to a head of treasury operations at a $10B bank tell a story about how she fixed delays in ACH underwriting. Traditionally, underwriting was conducted by credit department, which asked credit applicants the kinds of things a credit analyst would ask for. These included three years of financial statements describing revenue, net worth, liquidity, profitability, debt service coverage and debt/income.

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07 Apr

OCC-FDIC-CFPB Regulatory Olympics

 

 

The creation of the CFPB by the Dodd-Frank Act of 2010 not only added another financial regulator, it has changed the dynamics of existing regulators. Like an athletic team that has drafted a new player, the incumbents have found themselves sometimes competing, sometimes collaborating.

Or as one bank panelist at the ETA Transact 15 conference in San Francisco put it last week, “we now have the regulatory Olympics.”

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