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In simpler times, most high risk websites could be detected by crawling and classifying the public web.

But as acquirers, processors and ISOs become more effective at stopping online fraud and prohibited activity, bad actors have gone underground. There are various means to do this. An increasingly attractive ploy is transaction laundering (TL).

 

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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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