Tag: AML

You, Me, and Everyone You Know – The Impact of FinCEN’s Beneficial Ownership Requirements

If you’re a payment facilitator, how much do you currently know about the owners of your sub-merchant customers? If you’re a processor, how much do you know about the owners of your payment facilitator customer’s sub-merchant customers? And if you’re a bank, how much do you know about the owners of your processor customer’s payment facilitator customer’s sub-merchant customers (who are, technically, also your customers)?

Compliance in 2018: “Consumer Harm” Still Front and Center

Last year was a regulatory year to watch in the U.S., as a new – more anti-regulation – administration took the helm.

And it certainly did deliver some drama as CFPB Director Cordray departed, kicking off a fight for control of that agency.

We asked Deana Rich, CEO of Rich Consulting, to go beyond the spectacle and talk about any impact the new administration has had on regulatory issues and what payment facilitators should watch for in 2018.

4 Things PFs Need to Know About Anti-Money Laundering

Government regulations laid out by the Bank Secrecy Act and the USA PATRIOT Act require businesses to follow certain practices to avoid facilitating criminal activity, even inadvertently. Together, these regulations form the backbone of anti-money laundering efforts in the U.S.

These government regulations are supported by card brand rules that provide direction on payment facilitators’ specific roles and responsibilities. This is an area that can be daunting to many new and even seasoned payment facilitators.

Dr. Heather Mark, Ph.D., director of compliance for ProPay, shared four critical AML practices the payment facilitators she meets do not always fully understand.

When Treasury Speaks, PFs Should Listen

The U.S. Treasury clarified its anti money laundering regulations regarding foreign correspondent banks Aug. 30 and the attention it got was a reminder how weighty the Treasury’s words are to those in the payments world. Any time the Treasury speaks about AML PFs should listen, says Deana Rich, president of Rich Consulting.

Rich, a compliance expert, says KYC and AML and transaction monitoring are all practices that the technology companies who become payment facilitators are not used to overseeing, so attention to detail is highly recommended.


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