The Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule raising statutory fines for violating the Bank Secrecy Act (BSA). In some cases the maximum penalty amounts or ranges have…
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…
I recently attended the Third-Party Payment Processors Association (TPPPA) Executive Leadership Summit in Arizona where there were many interesting and informative presentations from attorneys, the Attorney General from the State of Arizona and others. The following are some of the key points that…
By the time the FDIC Inspector General largely cleared the FDIC of claims it coerced banks to “de-risk” certain high-risk businesses, alleged victims of Operation Choke Point were used to being on the losing end of judgments. But then something unexpected happened a few days later…
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.
With the presidential election upcoming in 16 months, bank regulations are becoming an increasing part of the national discourse. Even Rick Perry said he wants to break up banks, putting him in the same company as President Obama and Elizabeth Warren.
More central to the debate than bank size is consumer protection. What is the right amount of consumer protection?
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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