On January 19, 2021, several federal banking regulators including FinCEN, the Federal Reserve, the FDIC, NCUA, and the OCC jointly issued answers to several frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering (AML) considerations for financial institutions covered by SAR rules.  As used below, the term “financial institution” includes money …

A variety of important provisions in contracts for payment services are being significantly impacted by COVID-19. If you are concerned about a party’s ability to meet the obligations of an agreement – your own or the other side’s — it is important to evaluate those terms and conditions carefully to determine if and how the …

 An increase in chargebacks due to the current environment leads to Visa, Mastercard, and American Express issuing guidance to assist acquirers, issuers, and merchants in navigating the dispute process.

In light of COVID-19 developments, we have prepared tips for ISOs, processors, payment facilitators, ISVs, money services businesses, and banks.  

As of January 1, 2020, the California Consumer Privacy Act (CCPA) is now in effect. As we explained here, the CCPA imposes requirements on merchants and payment processors to protect personal information of California residents. Enforcement of the law does not begin until July 1, 2020, which is good because the regulations interpreting the law …

A federal court’s interpretation of a merchant contract resulted in the merchant not being liable for card brand security breach assessments. It may be worthwhile to examine and revise your merchant agreement in light of that ruling. In Specs v. First Data, decided June 2019, the US Court of Appeals for the Sixth Circuit ruled …