The FFIEC manual references “business type” as a risk factor 342 times, almost as many mentions as correspondent banks. Recent events in the payments processing industry have highlighted the need for commercial banks and TPPPs to adopt…
Coming out of ACAMS 15th annual AML & Financial Crime Conference in Las Vegas last week, I saw several themes emerging in the AML/BSA/KYC space. The conference featured an impressive array of speakers and exhibitors from the commercial banking industry, fintech and…
Last week, five heavy-hitters of US banking regulations released a joint fact sheet on Foreign Correspondent Banking. They took care to emphasize one flavor of…
The Consumer Financial Protection Bureau’s (CFPB’s) definition of “covered person” has taken on new meaning with the repercussions of the CFPB’s…
The new Customer Due Diligence Final Rule announced by FinCEN last week was less radical than some anticipated. It has been called both…
Last month further indictments were handed down related to the $4.9 million CommerceWest Bank settlement. The Justice Department charged Gareth Long, owner of Third-Party Payment Processor (TPPP) V Internet, with wire fraud and…
I was pleased to attend the recent WesPay Payments Symposium in Henderson, NV. There was a record turnout and a well-organized program of interesting speakers. What follows are some musings from…
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?
Both banks and their regulators have been focusing on the issue of higher risk customers with differing points of view as to how to deal with them. There is no standard definition of what is “higher risk” but some business categories which typically fall into that classification are online gambling, tobacco products, casinos, etc. There seems to be guidance from some regulatory agencies that…
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