Posts Tagged ‘FinCEN’
Merchant Settlement: Pros and Cons of Handling the Funds When You’re a PF
Since its inception, the payment facilitator model has been built on improving the client experience. Reducing and even eliminating onboarding delays to get merchants up and processing payments quickly is a hallmark of the business.
Read MoreMoney Transmission in the Payment Facilitator Model
The payment facilitator model continues to grow in popularity in the merchant acquiring space as a way to board merchants quickly and with minimal friction. While there are many benefits to this model, payment facilitators and their sponsoring banks and processors should be aware of the potential money transmission risks.
Read MoreReady for GDPR? The Next Compliance Deadline is Looming
Last week, it was FinCEN’s new beneficial ownership rules. Now, the General Data Protection Regulation (GDPR) – the new set of European data privacy standards – goes into effect next week.
Read MoreKYC 2.0: Beneficial Ownership Rule Takes Effect This Week
With the effective date of FinCEN’s new beneficial ownership rule coming up this week, we hope you have your plans in place. Still looking to understand the rule? We’ve pulled together some previous PaymentFacilitator coverage to help guide you through.
Read MorePart II: You, Me, and Everyone You Know – The Impact of FinCEN’s Beneficial Ownership Requirements
In part I of this series, we discussed the impact of the beneficial ownership rule on banks and their payment facilitator relationships. In this installment we discuss how the beneficial ownership rules apply to a bank acting as an originating depository financial institution for Automated Clearing House (ACH) transactions and its relationships with Originators, Third-Party Service Providers, and Third-Party Senders.
Read MoreYou, 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)?
Read MoreHoly KYC, Batman! New 2018 Rules Require PFs to Perform KYC on up to Five Owners
Don’t worry, technology is on your side and the PF model and frictionless underwriting will endure.
Read MoreCustomer Due Diligence Requirements are Changing for Financial Institutions. What Does This Mean for PayFacs?
Financial transparency and security are important. FinCEN and the staffs of the Federal functional regulators and the Department of Justice agree. As such, FinCEN has determined that more explicit rules for covered financial institutions with respect to Customer Due Diligence (CDD) are necessary to clarify and strengthen CDD within the Bank Secrecy Act (BSA) regime.
Read MoreTake A Deep Breath PFs, Beneficial Ownership Rule Is Not So Bad
First things first: In our opinion, the Treasury’s May 11 FinCEN rules are going to impact ISOs and Payment Facilitators alike, in that banks are going to make them follow these new rules.
Although the rule does not speak to ISOs or PFs underwriting merchants or submerchants, we fully believe if you are required to do KYC now — and ISOs and PFs are required to do KYC now — they will be required to do the increased KYC under the new rules.
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