Risk Management in US MSB Institutions

Introduction The US Bank Secrecy Act (“BSA”) requires that every Money Services Businesses (“MSB”) implement a BSA/Anti-Money Laundering (“AML”) Compliance Program.  Risk assessments provide a clear view as to the organization’s policies and procedures. Failure to implement a comprehensive BSA/AML Compliance Program may result in significant fines and/or penalties by state and federal regulators. So,…

Details

Digital vs. Cash, are we getting it all wrong?

This article was conceived after discussing with colleagues in the industry why the payments world has been driven into the Cash vs. Digital dichotomy. My research on cash has been inspired by analyzing the penalization of cash-based industries, such as the money transfer industry by the banking sector, which has resulted in the derisking phenomenon…

Details

The Antimonopoly Prosecutor in Chile sides with MSBs on Bank Account Closures

We thank our colleague Carlos Grossman, for the report out of Chile where the Antimonopoly Division of the National Economic Prosecutor Office (División Antimonopolios de la Fiscalía Nacional Económica – FNE)  reports the investigation that took place after an August 2015 complaint by a Forex Firm denouncing seven banks of denying the opening of a…

Details

Identity Matching in the Money Transfer & Payments Industry

I am going to venture myself to write this article on Compliance, with the disclaimer that I am not a compliance professional and that the idea behind this is to get compliance colleagues to comment and compliance officers to pay attention. Talking last week to a fintech company about their payment processing services in Mexico,…

Details

Blockchain-based solutions to the Caribbean derisking problem

De-risking was an acute illness for the Caribbean financial sector in 2015 and 2016. In 2017, the height of the fever has broken, but the patient is still sick. Though correspondent banks in developed countries are no longer dropping services to Caribbean banks at a rapid pace, the region’s economies remain encumbered with a residue…

Details